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of <h1>Article 12: Double Tax Agreement Caps Tax on Royalties and Technical Fees at 10% for Beneficial Owners.</h1> Article 12 of the Double Tax Avoidance Agreement between two Contracting States addresses the taxation of royalties and fees for technical services. These payments, when arising in one State and paid to a resident of the other, may be taxed in both States, with the tax in the source State capped at 10% if the recipient is the beneficial owner. Royalties include payments for the use of intellectual property, while fees for technical services cover managerial, technical, or consultancy services. Exceptions apply if the recipient has a permanent establishment or fixed base in the source State. Special relationships affecting payment amounts are addressed, ensuring only the arm's length amount is subject to the provisions.
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