Introducing the “In Favour Of” filter in Case Laws.
- ⚖️ Instantly identify judgments decided in favour of the Assessee, Revenue, or Appellant
- 🔍 Narrow down results with higher precision
Try it now in Case Laws →
TaxTMI Login
🚀 New Feature Launched ✕
Just a moment...
Introducing the “In Favour Of” filter in Case Laws.
Try it now in Case Laws →
Press 'Enter' to add multiple search terms. Rules for Better Search
of 
of 
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of of 
All Acts & Rules
of of All Acts & Rules
Note
Bookmark
Share
Don't have an account? Register Here
of <h1>Article 12 of DTAA Caps Tax on Royalties and Technical Service Fees at 10% if Beneficial Owner</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of royalties and fees for technical services. These payments, arising in one state and paid to a resident of the other, may be taxed in both states. However, if the recipient is the beneficial owner, the tax in the originating state is capped at 10% of the gross amount. 'Royalties' include payments for intellectual property use, while 'fees for technical services' cover managerial, technical, or consultancy services. Exceptions apply if the recipient has a permanent establishment or fixed base in the originating state. Special relationships affecting payment amounts are also addressed.
TaxTMI 
TaxTMI 
