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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% if Beneficial Owner; Excludes Natural Resources, Adjustments for Special Relationships</h1> Royalties arising in one Contracting State and paid to a resident of another may be taxed in both states, with the source state limiting tax to 10% if the recipient is the beneficial owner. Royalties include payments for the use of copyrights, patents, trademarks, and industrial equipment, but exclude natural resource operations. The tax provisions do not apply if the beneficial owner has a permanent establishment in the source state connected to the royalties. Royalties are considered to arise in the state where the payer resides or has a permanent establishment. Special relationships affecting royalty amounts are subject to adjustments.
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