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of <h1>Uganda's DTAA Article 12: Taxation of Royalties and Fees for Technical Services Capped at 10% for Beneficial Owners</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between Uganda and another Contracting State addresses the taxation of royalties and fees for technical services. Such payments, originating in one Contracting State and paid to a resident of the other, may be taxed in both states, with a maximum tax rate of 10% in the originating state if the recipient is the beneficial owner. Royalties cover payments for the use of intellectual property, while fees for technical services include managerial and consultancy services. Exceptions apply if the recipient conducts business through a permanent establishment in the originating state. Payments are deemed to arise in the state of the payer unless linked to a permanent establishment elsewhere. Special relationships affecting payment amounts are subject to specific taxation rules.
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