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of <h1>Royalties Taxed in Both States, Capped at 10% if Beneficial Owner is Resident Elsewhere; Special Rules for Permanent Establishments.</h1> Royalties arising in one Contracting State and paid to a resident of the other may be taxed in both states, with the tax in the state of origin not exceeding 10% if the beneficial owner is a resident of the other state. 'Royalties' include payments for the use of intellectual property, equipment, or information. The provisions do not apply if the royalties are connected to a permanent establishment or fixed base in the state of origin. Royalties are deemed to arise where the payer is a resident or where a permanent establishment incurs the liability. Excessive payments due to special relationships are taxable under each state's laws.
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