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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 12: Taxation of Royalties and Technical Fees Capped at 15% Under Double Tax Avoidance Agreement</h1> Article 12 of the Double Tax Avoidance Agreement between the Kyrgyz Republic and another Contracting State addresses the taxation of royalties and fees for technical services. These payments, originating 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 originating state is capped at 15% of the gross amount. Royalties cover payments for the use of copyrights, patents, and equipment, while fees for technical services include managerial and consultancy services. Exceptions apply if the recipient has a permanent establishment in the originating state.
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