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of <h1>Article 12: Double Taxation Agreement Caps Tax on Royalties and Technical Fees at 10% with Specific Conditions</h1> Article 12 of the Double Taxation Avoidance Agreement between Ireland and another Contracting State addresses the taxation of royalties and fees for technical services. These payments, made to a resident of one Contracting State, can be taxed in both the receiving and originating States, with a maximum tax rate of 10% if the recipient is the beneficial owner. 'Royalties' include payments for the use of intellectual property and equipment, while 'fees for technical services' cover managerial and consultancy services. Exceptions apply if the recipient has a permanent establishment in the paying State. Payments exceeding fair market value due to special relationships are taxed differently.
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