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of <h1>Royalties Taxation Under Article 12 of DTAA: Dual Taxation Rules, 15% Cap, and Exceptions for Permanent Establishments</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of royalties. Royalties paid to a resident of one State by a resident of another may be taxed in the recipient's State, but can also be taxed in the State where they arise, capped at 15% of the gross amount. 'Royalties' include payments for the use of intellectual property and certain equipment. Exceptions apply if the recipient has a permanent establishment in the source State. Additionally, if a special relationship affects the royalty amount, only the arm's length portion is subject to these provisions.
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