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of <h1>Article 12 of DTAA: Taxation Rules for Royalties and Service Fees Between Contracting States Explained</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of royalties and fees for included services. Such payments, arising in one state and paid to a resident of the other, may be taxed in both states. However, if the beneficial owner resides in the other state, the tax is capped at specific rates. Royalties cover payments for the use of intellectual property, while fees for included services pertain to technical or consultancy services. Exceptions apply when the payer has a permanent establishment in the state where the services arise, and special relationships affecting payment amounts are also considered.
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