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of <h1>Article 13 of Korea's DTAA: Taxation on Royalties and Technical Service Fees Capped at 15% for Beneficial Owners.</h1> Article 13 of the Double Tax Avoidance Agreement (DTAA) between Korea and another Contracting State addresses the taxation of royalties and fees for technical services. These payments, made to a resident of one Contracting State, can be taxed in both the state where they arise and the recipient's state, with a maximum tax rate of 15% if the recipient is the beneficial owner. 'Royalties' cover payments for the use of intellectual property, while 'fees for technical services' include payments for managerial, technical, or consultative services. Exceptions apply if the recipient conducts business through a permanent establishment in the state where payments arise.
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