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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 12 of DTAA: Taxation of Royalties and Service Fees Limited by Residency and Special Conditions.</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between two contracting states addresses the taxation of royalties and fees for included services. These payments, arising in one state and paid to a resident of the other, may be taxed in both states, but with limits on tax rates if the beneficial owner resides in the other state. The article defines 'royalties' and 'fees for included services' and outlines specific conditions and exceptions for their taxation. It also addresses scenarios involving permanent establishments and special relationships affecting payment amounts, ensuring taxation aligns with the treaty's provisions.
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