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of <h1>Article 12 of OECD and UN Models: Taxation of Royalties and Permanent Establishment Rules Explained</h1> Article 12 of the OECD and UN Model Tax Conventions outlines the taxation of royalties between Contracting States. Under the OECD model, royalties are taxable only in the state where the beneficial owner resides unless the owner has a permanent establishment in the state where the royalties arise. In such cases, Article 7 applies. The UN model allows taxation in both states, with a limit on the tax rate in the state where the royalties arise, subject to bilateral negotiation. Royalties are defined as payments for the use of copyrights, patents, trademarks, and similar rights.
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