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of <h1>Royalties Taxed at Max 10% if Beneficial Owner; Includes Payments for Copyrights, Patents, and Trademarks.</h1> Royalties arising in one Contracting State and paid to a resident of another may be taxed in the recipient's State but can also be taxed in the State where they originate, with a maximum tax rate of 10% if the recipient is the beneficial owner. 'Royalties' include payments for the use of copyrights, patents, trademarks, and similar intangible properties. Exceptions apply if the beneficial owner has a permanent establishment or fixed base in the State where royalties arise. Royalties are deemed to arise where the payer resides or has a permanent establishment. Special relationships affecting royalty amounts are subject to standard taxation rules.
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