Royalties arising in a Contracting Clause Samples
The 'Royalties arising in a Contracting' clause defines how royalties generated within one of the contracting states are to be treated, typically for tax or payment purposes. It specifies the conditions under which royalties—such as payments for intellectual property, copyrights, or patents—are considered to originate from a particular country, and may outline the tax obligations or withholding requirements for such payments. This clause ensures that both parties understand where royalties are deemed to arise, thereby clarifying tax liabilities and preventing double taxation or disputes over jurisdiction.
Royalties arising in a Contracting. State and paid to a resident of the other Contracting State may be taxed in that other State.
Royalties arising in a Contracting. State and paid to a resident of the other Contracting State shall be taxable only in that other State if such resident is the beneficial owner of the royalties.