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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 13 of DTAA: Tax on Royalties and Technical Fees Capped at 10% for Beneficial Owners with Exceptions.</h1> Article 13 of the Double Taxation Avoidance Agreement (DTAA) between Spain and another Contracting State addresses the taxation of royalties and fees for technical services. These payments, arising in one state and paid to a resident of the other, may be taxed in both states, but the tax in the state of origin is capped at 10% if the recipient is the beneficial owner. Royalties include payments for the use of intellectual property and technical services, excluding employee payments. Exceptions apply if the recipient has a permanent establishment in the state of origin. Special relationships affecting payment amounts are also addressed.
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