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of <h1>Article 12 of DTAA: Royalties Taxed in Both States, Capped at 10% in Source State if Beneficial Owner.</h1> Article 12 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of royalties. Royalties paid to a resident of one Contracting State may be taxed in both the state where they arise and the state of residence, with a tax cap of 10% in the source state if the recipient is the beneficial owner. Royalties refer to payments for the use of copyrights, patents, trademarks, and similar rights. Exceptions apply if the royalties are connected to a permanent establishment. Special relationships affecting royalty amounts are subject to standard taxation rules.
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