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of <h1>DTAA Article 13: Taxation Rules for Technical Service Fees with 10% Cap if Beneficial Owner, Exclusions Apply</h1> Article 13 of the Double Tax Avoidance Agreement (DTAA) between Malaysia and another Contracting State outlines the taxation of fees for technical services. Such fees, when derived by a resident of one Contracting State, may be taxed in the other State. However, they can also be taxed in the State where they arise, with a tax cap of 10% if the recipient is the beneficial owner. The term excludes payments covered under Articles 14 and 15. Exceptions apply if the fees are connected to a permanent establishment or fixed base. Special relationships affecting fee amounts are addressed separately.
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