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of <h1>Article 14 of Namibia DTAA: Technical Service Fees Tax Capped at 10% for Beneficial Owners; Exceptions Apply</h1> Article 14 of the Double Tax Avoidance Agreement (DTAA) between Namibia and another Contracting State addresses the taxation of fees for technical services. Such fees, derived by a resident of one Contracting State from the other, may be taxed in both states, but the tax in the state where the fees arise is capped at 10% if the recipient is the beneficial owner. The term 'fees for technical services' includes payments for technical, managerial, or consultancy services, excluding employee payments. Exceptions apply if the fees are connected to a permanent establishment or independent services in the other state, invoking other articles of the agreement. Special relationships affecting fee amounts are also considered, with excess amounts taxable under respective state laws.
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