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<h1>Understanding Article 12 of the DTAA: Taxation on Royalties and Service Fees with a 15% Cap Until 2017</h1> Article 12 of the Double Taxation Avoidance Agreement (DTAA) between Cyprus and another Contracting State, effective until March 31, 2017, addresses the taxation of royalties and fees for included 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 is capped at 15% if the recipient is the beneficial owner. Royalties cover payments for the use of intellectual property, equipment, and media, while fees for included services relate to technical assistance and consultancy. Exceptions apply if the recipient has a permanent establishment in the source state.