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of <h1>Royalties Taxed in Both States; Source State Tax Capped at 10% Unless Article 7 Applies for Permanent Establishments.</h1> Royalties arising in one Contracting State and paid to a resident of another may be taxed in both states, with the source state's tax capped at 10% of the gross amount. 'Royalties' include payments for the use of copyrights, patents, trademarks, and similar rights. If the recipient has a permanent establishment in the source state, Article 7 applies instead. Royalties are considered to arise in the state where the payer is a resident or has a permanent establishment. If a special relationship inflates the royalty amount, only the standard amount is subject to these provisions, with excess taxed separately.
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