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of <h1>Royalties Taxed in Both States: Max 10% Tax if Beneficial Owner Resides Elsewhere; Exceptions for Business Operations.</h1> Royalties arising in one Contracting State and paid to a resident of another may be taxed in both states, with the tax in the originating state not exceeding 10% if the beneficial owner resides in the other state. 'Royalties' include payments for the use of copyrights, patents, and industrial equipment. Exceptions apply if the beneficial owner operates a business or provides services through a permanent establishment in the originating state. Royalties are deemed to arise in the state where the payer resides or has a permanent establishment. Excessive payments due to special relationships are taxed according to each state's laws.
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