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of <h1>DTAA Article 14: Taxation Rules for Royalties and Technical Fees Between Romania and Another State, Tax Cap at 22.5%</h1> Article 14 of the Double Taxation Avoidance Agreement (DTAA) between Romania and another Contracting State addresses the taxation of royalties and fees for technical services. These payments, when arising in one Contracting State and paid to a resident of the other, may be taxed in the recipient's state but also in the state where they originate, with a tax cap of 22.5% if the recipient is the beneficial owner. Definitions for 'royalties' and 'fees for technical services' are provided, and exceptions are outlined for business operations connected to a permanent establishment. Special relationships affecting payment amounts are also addressed, with excess payments being taxable under each state's laws.
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