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of <h1>Royalties Taxed in Both States; Trademark Royalties Capped at 25%, Others at 15% if Beneficial Owner</h1> Royalties arising in one Contracting State and paid to a resident of another may be taxed in both states, with limits on the tax rate if the recipient is the beneficial owner. The tax on royalties for trademarks is capped at 25% and 15% for other cases. Royalties include payments for the use of intellectual property and industrial equipment. The provisions do not apply if the recipient has a permanent establishment in the state where the royalties arise. Royalties are considered to arise where the payer is located unless tied to a permanent establishment elsewhere. Excess payments due to special relationships are taxed separately.
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