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of <h1>DTAA Article 12: Royalties Taxed in Both States, Capped at 15% for Intellectual Property and Equipment Use</h1> Article 12 of the Double Taxation Avoidance Agreement (DTAA) between Thailand and another Contracting State addresses the taxation of royalties. Royalties paid to a resident of one Contracting State by a resident of the other may be taxed in the recipient's state but also in the state where they arise, with a maximum tax rate of 15% on the gross amount. 'Royalties' cover payments for the use of intellectual property, industrial equipment, or scientific experience. Exceptions apply if the recipient has a permanent establishment in the source state. Royalties are deemed to arise in the state of the payer or where a permanent establishment is situated. Special relationships affecting royalty amounts are addressed separately.
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