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of <h1>Article 13 of DTAA Limits Technical Fees Taxation to 10% for Beneficial Owners with Specific Exceptions</h1> Article 13 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of technical fees. Technical fees paid to a resident of one Contracting State by a resident of the other may be taxed in both States, with a maximum tax rate of 10% in the State where the fees arise, provided the recipient is the beneficial owner. The term 'technical fees' refers to payments for technical, managerial, or consultancy services. Exceptions apply if the fees are connected to a permanent establishment or independent services in the State where the fees arise. Special relationships affecting fee amounts are subject to specific provisions.
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