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of <h1>Article 13 of Cyprus DTAA Caps Tax on Technical Fees at 10% for Beneficial Owners; Defines Scope and Special Provisions</h1> Article 13 of the Double Tax Avoidance Agreement (DTAA) between Cyprus and another Contracting State addresses the taxation of technical fees. These fees, when derived by a resident of one Contracting State from the other, may be taxed in the resident's State. However, they can also be taxed in the State where they arise, with a cap of 10% if the recipient is the beneficial owner. Technical fees are defined as payments for technical, managerial, or consultancy services, excluding employee payments. Special provisions apply if the fees relate to a permanent establishment or independent services in the other State. Additionally, excess payments due to special relationships are subject to specific tax rules.
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