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of <h1>Taxation of Royalties and Technical Fees under DTAA Article 12: Dual Taxation with 10% Cap for Beneficial Owners.</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of royalties and fees for technical services. Such payments, if arising in one State and paid to a resident of the other, can be taxed in both States, with a maximum tax rate of 10% if the recipient is the beneficial owner. 'Royalties' include payments for the use of intellectual property and certain equipment, while 'fees for technical services' cover managerial, technical, or consultancy services, excluding specific categories like personal services and educational teaching. Exceptions apply if the beneficial owner operates through a permanent establishment in the other State.
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