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of <h1>Article 13: Taxation Rules for Royalties and Technical Fees in Double Taxation Agreement, Max Rate 15% if Beneficial Owner.</h1> Article 13 of the Double Taxation Avoidance Agreement between two unnamed Contracting States addresses the taxation of royalties and fees for technical services. Such payments made to a resident of one Contracting State may be taxed in the other State. However, they may also be taxed in the State where they arise, subject to a maximum tax rate of 15% if the recipient is the beneficial owner. Definitions for 'royalties' and 'fees for technical services' are provided, and exceptions apply if the recipient has a permanent establishment in the State where the payments arise. Special relationships affecting payment amounts are also considered.
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