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of <h1>Article 13 of DTAA: Tax on Royalties and Fees for Technical Services Capped at 20% for Beneficial Owners</h1> Article 13 of the Double Tax Avoidance Agreement (DTAA) between Denmark and another Contracting State addresses the taxation of royalties and fees for technical services. These payments, when arising in one Contracting State and paid to a resident of the other, may be taxed in both states. However, if the recipient is the beneficial owner, the tax in the source state is capped at 20% of the gross amount. The article defines 'royalties' and 'fees for technical services' and specifies conditions under which the provisions do not apply, particularly involving permanent establishments or fixed bases. Special relationships affecting payment amounts are also addressed.
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