Royalties withholding limit for beneficial owners restricts source-state tax; PE or fixed base exceptions link to business profits rules.

Royalties may be taxed in the recipient's State, while the source State may also tax them subject to a statutory withholding cap when the recipient is the beneficial owner. The Article provides a wide definition of royalties and excludes the withholding rule where royalties are effectively connected with a permanent establishment or fixed base in the source State, in which case business profits or independent personal services rules apply. Source is determined by the payer's residence or by the payer's permanent establishment or fixed base bearing the liability. Special-relationship amounts are adjusted to arm's-length for application of the Article.

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