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of <h1>DTAA Article 12: Taxation Rules for Royalties and Technical Fees Capped at 10% in Source State</h1> Article 12 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States 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 state where they arise and the state of the recipient, with a maximum tax rate of 10% in the source state if the recipient is the beneficial owner. Royalties include payments for the use of intellectual property and technical services, excluding those covered by other articles of the agreement. Exceptions apply if the recipient has a permanent establishment in the source state. Special relationships affecting payment amounts are also addressed.
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