Royalties taxation limit: source state withholding capped where beneficial owner is nonresident, with PE exceptions and related party adjustments.

Royalties may be taxed in the recipient's State of residence and in the source State, with a source state withholding cap when the beneficial owner is resident in the other Contracting State. Broadly defined royalties include payments for use of copyrights, patents, trademarks, designs, equipment, and technical information. The withholding cap is inapplicable where royalties are effectively connected to a permanent establishment or fixed base in the source State, and deemed source rules and arm's length adjustments govern allocation and treaty relief.

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