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of <h1>Royalty Payments Across Borders: Navigating Taxation Rules for International Intellectual Property Transfers</h1> The UN Model Double Tax Avoidance Agreement Article 12 governs royalty taxation between contracting states. It allows taxation of royalties in the recipient's state, with potential additional taxation in the source state up to a mutually negotiated percentage. The provision defines royalties broadly, covering copyrights, patents, trademarks, and technical information. Special provisions address situations involving permanent establishments, and mechanisms exist to prevent excessive payments through special relationships between parties.
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