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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>DTAA Article 12: Tax on Royalties and Technical Services Capped at 10% if Beneficial Owner, with Specific Exceptions</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) 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, can be taxed in both States. However, if the recipient is the beneficial owner, the tax in the source State is capped at 10% of the gross amount. Definitions are provided for 'royalties' and 'fees for technical services.' Exceptions apply if the beneficial owner operates a business or provides services through a permanent establishment or fixed base in the source State. Payments exceeding fair market value due to special relationships are subject to different tax treatment.
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