Royalties taxation: source-state withholding limited where beneficial owner is resident elsewhere; PE-connected royalties follow business rules. Royalties may be taxed in the recipient's State, while the source State may also tax them subject to a withholding tax limitation when the beneficial owner is resident of the other Contracting State. Royalties are defined to include payments for use of copyrights, patents, trademarks, designs, industrial/commercial/scientific equipment and proprietary information. The withholding limits do not apply where the beneficial owner's rights are effectively connected with a permanent establishment or fixed base in the source State; deemed-source rules determine where royalties arise and an anti-abuse provision limits application to arm's-length amounts when special relationships inflate payments.