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of <h1>Article 12 of DTAA Limits Tax on Royalties to 10% for Beneficial Owners; Defines 'Royalties' and Exceptions</h1> Article 12 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of royalties. Royalties paid to a resident of one Contracting State by another may be taxed in the recipient's State. However, they can also be taxed in the State where they arise, with a tax cap of 10% if the recipient is the beneficial owner. 'Royalties' include payments for the use of copyrights, patents, trademarks, and similar rights. Exceptions apply if the royalties are connected to a permanent establishment. Special relationships affecting royalty amounts are subject to specific provisions.
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