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of <h1>Article 12 of DTAA: Royalties & Fees for Technical Services Taxed Up to 10% if Beneficial Owner</h1> Article 12 of the Double Taxation Avoidance Agreement (DTAA) between two countries outlines the taxation of royalties and fees for technical services. These payments, arising in one Contracting State and paid to a resident of the other, may be taxed in both states, but the tax in the source state should not exceed 10% if the recipient is the beneficial owner. Royalties include payments for the use of copyrights, patents, and other intellectual properties, while fees for technical services cover managerial, technical, or consultancy services. Special provisions apply if the beneficial owner operates through a permanent establishment in the source state.
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