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of <h1>Royalties Taxed in Both States with 15% Cap if Beneficial Owner; Exceptions for Business Operations.</h1> Royalties arising in one Contracting State and paid to a resident of another may be taxed in the resident's State, but also in the State where they arise, with a tax cap of 15% if the recipient is the beneficial owner. Royalties encompass payments for using intellectual property, patents, or equipment. Exceptions apply if the beneficial owner operates a business or provides services through a permanent establishment in the State where royalties arise. Royalties are deemed to arise where the payer resides or maintains a permanent establishment. Excess payments due to special relationships are taxable under each State's laws.
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