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of <h1>Kenya's DTAA Article 15: Management & Professional Fees Taxed at 0.5% Cap, Excluding Employee Payments</h1> Article 15 of the Double Tax Avoidance Agreement (DTAA) between Kenya and another Contracting State addresses the taxation of management and professional fees. These fees, paid to a resident of one Contracting State by another, can be taxed in the recipient's State. However, the State where the fees arise may also tax them, capped at 0.5% of the gross amount. The term covers payments for managerial, technical, professional, or consultancy services, excluding employee payments. If the recipient has a permanent establishment in the fee-originating State, Article 7 applies. Special relationships affecting fee amounts are subject to specific provisions.
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