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of <h1>Article 12 of DTAA: Taxation Rules for Royalties and Technical Service Fees Between Contracting States Explained</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of royalties and fees for technical services. These payments, arising in one State and paid to a resident of the other, may be taxed in both States, with a cap of 15% if the recipient is the beneficial owner. 'Royalties' cover payments for the use of intellectual property and equipment, while 'fees for technical services' involve managerial, technical, or consultancy services. Exceptions apply if the recipient has a permanent establishment in the paying State. Payments exceeding fair amounts due to special relationships are taxed according to each State's laws.
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