Introducing the “In Favour Of” filter in Case Laws.
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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Royalties Taxed in Both States, Capped at 10% for Beneficial Owners; Exclusions for Permanent Establishments Apply.</h1> Royalties arising in one Contracting State and paid to a resident of another may be taxed in both states, but the tax in the state of origin cannot exceed 10% if the recipient is the beneficial owner. 'Royalties' include payments for the use of copyrights, patents, trademarks, and similar rights. These provisions do not apply if the recipient has a permanent establishment in the state of origin, in which case other articles apply. Royalties are considered to arise where the payer resides, unless linked to a permanent establishment. Excess payments due to special relationships are taxed separately.
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