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of <h1>Article 12 of DTAA: Tax Rules for Royalties and Technical Service Fees, 10% Cap for Beneficial Owners</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of royalties and fees for technical services. These payments, arising in one State and paid to a resident of the other, may be taxed in both States, with the source State's tax capped at 10% if the recipient is the beneficial owner. 'Royalties' include payments for the use of copyrights, patents, and similar rights, while 'fees for technical services' cover managerial or consultancy services. Exceptions apply if the recipient has a permanent establishment in the source State. Payments exceeding fair market value due to special relationships are only partially covered by this Article.
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