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<h1>Article 12 of Malta DTAA Caps Royalty and Service Fees Tax at 15% for Beneficial Owners</h1> Article 12 of the Double Taxation Avoidance Agreement (DTAA) between Malta and another Contracting State outlines the taxation of royalties and fees for included services. Such payments, when arising in one state and paid to a resident of the other, may be taxed in both states, with a cap of 15% in the state where they arise if the recipient is the beneficial owner. Royalties cover payments for the use of intellectual property, equipment, or information, while fees for included services relate to ancillary assistance or technical services. Exceptions apply if the beneficial owner has a permanent establishment or fixed base in the paying state. Payments exceeding fair market value due to special relationships are only partially covered by this Article.