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of <h1>Namibia's DTAA Article 12: Royalties Taxed at Max 10% if Beneficial Owner; Exceptions for Business Presence Apply.</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between Namibia and another Contracting State addresses the taxation of royalties. Royalties paid to a resident of the other Contracting State may be taxed in that State, but can also be taxed in the State where they arise, with a maximum tax rate of 10% if the recipient is the beneficial owner. Royalties include payments for the use of intellectual property and know-how. Exceptions apply if the recipient has a business presence in the State where the royalties arise. Special relationships affecting royalty amounts are also addressed, ensuring excess payments remain taxable.
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