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of <h1>Royalty Taxation Rules: Cross-Border Payments Governed by Specific Conditions and Recipient State Jurisdiction</h1> The statutory provisions outline taxation rules for royalties between contracting states. Key principles include: royalties are primarily taxable in the recipient's state, with specific exceptions for connected persons and expatriated entities. The provisions define royalties broadly, covering intellectual property usage, and address situations involving special relationships or permanent establishments. The text establishes conditions for taxation, rate limitations, and treatment of cross-border royalty payments under international tax conventions.
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