US-Germany income tax convention, Article 12: royalties taxable only in the country of the recipient (Convention between the United States and Germany (1989) as amended, Art. 12(1)-(2))

“Royalties derived and beneficially owned by a resident of a Contracting State shall be taxable only in that State. ... payments of any kind received as a consideration for the use of, or the right to use, any copyright of a literary, artistic, or scientific work (but not including cinematographic films, or works on film, tape, or other means of reproduction for use in radio or television broadcasting); for the use of, or the right to use, any patent, trademark, design or model, plan, secret formula or process, or other like right or property; or for information concerning industrial, commercial, or scientific experience.”

It is shown on its own, not counted into a figure.

Cited in this guide

• US Withholding Tax When a Foreign Company Licenses Data

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