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of <h1>Kazakhstan DTAA Article 12 Caps Source State Tax on Royalties, Technical Fees at 10% for Beneficial Owners</h1> Article 12 of the Double Taxation Avoidance Agreement (DTAA) between Kazakhstan and another Contracting State addresses the taxation of royalties and fees for technical services. Royalties or fees paid to a resident of one Contracting State by another may be taxed in both states, but the tax in the source state is capped at 10% if the recipient is the beneficial owner. 'Royalties' cover payments for the use of intellectual property and equipment, while 'fees for technical services' include payments for managerial and consultancy services. The article also outlines conditions where these provisions do not apply, such as when business is conducted through a permanent establishment. Special relationships affecting payment amounts are also addressed, limiting the application of these provisions to reasonable amounts.
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