Royalties tax limitation: source-state withholding capped for non-resident beneficial owners, with PE/fixed-base exceptions and transfer-pricing adjustment.

Article 12 allows royalties arising in a Contracting State and paid to a resident of the other State to be taxed in the recipient's State but also in the source State, subject to a capped source tax where the beneficial owner is a resident of the other State. Royalties are defined broadly to include payments for rights to use copyrights, films, patents, trademarks, designs, processes, equipment and technical information. Exceptions apply where the beneficial owner has a permanent establishment or fixed base and the right is effectively connected thereto, invoking the provisions on business profits or independent personal services. Special-relationship adjustments limit the Article's application to the arm's-length amount.

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