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of <h1>Article 13 of Double Tax Agreement: Taxation Rules for Technical Service Fees and Beneficial Ownership Conditions</h1> Article 13 of the Double Tax Avoidance Agreement between two contracting States addresses the taxation of fees for technical services. Such fees, paid to a resident of the other State, may be taxed in the recipient's State but also in the State where they arise, with a tax cap of 10% if the recipient is the beneficial owner. Technical services encompass managerial, technical, or consultancy services but exclude certain services. Exceptions apply if the fees are connected to a permanent establishment or fixed base. The article also outlines specific exclusions and conditions for related parties affecting fee amounts.
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