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of <h1>Article 12 of DTAA Caps Tax on Royalties and Technical Fees at 10% Between Contracting States</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between two contracting states addresses the taxation of royalties and fees for technical services. Such payments arising in one state and paid to a resident of the other may be taxed in both states, but the tax in the state where they arise shall not exceed 10% if the recipient is a resident of the other state. Royalties include payments for using copyrights, patents, and trademarks, while fees for technical services cover managerial, technical, or consultancy services. Exceptions apply if the recipient has a permanent establishment in the paying state.
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