Common use of Royalties Clause in Contracts

Royalties. (1) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings for radio and television, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment. (4) The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise to the royalties is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings films or tapes for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itself, a policitical subdivisionContracting State, a local authoritiy authority thereof or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments payment of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and recordings or tapes used for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article Articles 7 or Article and 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) Where, . Where by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and recordings or tapes used for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 1415, as the case may be, shall apply. (5) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 15 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind kind, received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work work, including cinematograph films, or films and recordings or tapes used for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply apply, if the beneficial owner of the royalties, royalties being a resident of a Contracting State, State carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case a case, the provisions of Article 7 or Article 1415, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivisionpolitical sub-division, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, royalties whether he is a resident of a Contracting State or not, not has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information information, for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments payment shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent 15 percent of the gross amount of the royalties. (3) . The term "" royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work work, including cinematograph films and recordings or films or tapes used for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right right, property or property contract in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority, or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, royalties paid exceeds the amount which would have been agreed upon by the payer and the beneficial owner paid in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 5 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work work, including cinematograph films, and films and recordings or tapes for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph cinematographic films, or films and recordings or tapes for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itselfContracting State, a policitical subdivision, an administrative subdivision or a local authoritiy authority thereof or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, relationship the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting Con- tracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties ▇▇▇- alties is a resident of the other Contracting State, the tax so charged shall not exceed 10 ten per cent of the gross amount of the royalties. The competent authorities of the Contract- ing States shall by mutual agreement settle the mode of application of this limitation. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings for radio and televisionfilms, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. It also includes payments for technical assistance performed in a Contracting State by a resident of the other State where such assistance is related to the application of any such right or property. The term "royalties" also includes gains re- ceived from the alienation of such right or property to the extent that such gains are con- tingent on the productivity, use, or for the use of, or the right to use, industrial, commercial or scientific equipmentdisposition thereof. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated situat- ed therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment establish- ment or a fixed base in connection with which the right or property giving rise obligation to pay the royalties is effectively connectedwas in- curred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment estab- lishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having hav- ing regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence ab- sence of such relationship, the provisions of this Article shall apply only to the last-last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions provi- sions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws law of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the such royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings for radio and televisionfilms, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. (2) . However, such royalties arising in a Contracting State may also be taxed in the that Contracting State in which they arise and according to the laws of that Contracting State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed exceed: (a) 3 per cent of the gross amount of the royalties for the use of, or the right to use, any news; (b) 5 per cent of the gross amount of the royalties for the use of, or the right to use, any copyright of literary, artistic or scientific work; (c) 10 per cent of the gross amount of the royaltiesroyalties in all other cases. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any news, any copyright of literary, artistic or scientific work including cinematograph films and recordings for radio and televisionwork, or any patent, trade mark▇▇▇▇, design or model, plan, or secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting Con- tracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent 10% of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. (3) . The term "«royalties" » as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work work, including cinematograph films and recordings for radio and televisionfilms, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting Con- tracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy or a resident resi- dent of that State. Where, however, the person paying the royalties, whether he is a resident resi- dent of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise obligation to pay the royalties is effectively connectedwas in- curred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment estab- lishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having royalties hav- ing regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence ab- sence of such relationship, the provisions of this Article shall apply only to the last-last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions provi- sions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 ten per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and recordings or tapes for radio and televisionor television broadcasting, any patent, trade marktrademark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, political subdivision or a local authoritiy authority thereof or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne born by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 5 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work work, including cinematograph films, and films and recordings or tapes for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings films or tapes for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itself, a policitical subdivisionContracting State, a local authoritiy authority thereof or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent 7.5% of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph cinematography films, or films and recordings or tapes for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 l and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itself, a policitical subdivisionContracting State, a local authoritiy authority thereof or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . The provisions of this Article shall not apply if the right giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bonafide commercial reasons. 7. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royaltiesroya1ties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic by an enterprise of a Contracting State or movable property pertaining to the operation of such ships or aircraft shall be taxable only in that State.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may shall be taxed taxable only in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 twelve and one half (12 1/2) per cent of the gross amount of the such royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to of use, any copyright of literary, artistic or scientific work including cinematograph films and recordings or tapes for radio and televisiontelevision or broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, State carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 1415, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such that case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the such royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and recordings or tapes used for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with (a) such permanent establishment or fixed base, or with (b) business activities referred to under (c) of paragraph 1 of Article 7. In such case cases the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, or a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and recordings or tapes used for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 1415, as the case may be, shall apply. (5) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings films or tapes for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that Contracting State itself, a policitical political subdivision, a local authoritiy authority or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph cinematography films, or films and recordings or tapes for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itself, a policitical subdivisionContracting State, a local authoritiy authority thereof or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, State the tax so charged shall not exceed 10 5 per cent of the gross amount of the royalties. (3) . Notwithstanding the provisions of paragraphs 1 and 2, royalties paid by a company which is a resident of a Contracting State shall be taxable only in the other Contracting State if the beneficial owner of the royalties is that other State itself, a political subdivision or local authority thereof or a financial institution which is a resident of that other Contracting State. 4. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings films or tapes for television or radio and televisionbroadcasting, any software, patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment. (4) 5. The provisions of paragraphs 1 1, 2 and 2 3 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) 6. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) 7. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable in the Contracting State in which the royalties arise, according to the laws of each Contracting that State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may shall be taxed taxable in that other State. (2) However. These royalties, such royalties may however, are also be taxed taxable in the Contracting State in which they arise and according to in accordance with the laws of that this State; however, but if in case the beneficial beneficiary owner of the royalties is a resident of the other Contracting State, the tax so charged shall levied in such a manner cannot exceed 10 per cent 15 percent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work work, including cinematograph films or films, tapes, and recordings other media for radio image and televisionsound reproduction, any patentpatents, trade markmarks, design designs or modelmodels, planplans, secret formula formulas or processprocesses or other intangible property as well as for the use or the right to use any industrial, commercial, or scientific equipment or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipmentknow-how. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business an entrepreneurial activity in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the property or right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) Royalties shall be . The royalties are deemed to arise in a Contracting State when in case the payer is that State itself, a policitical subdivision, a local authoritiy or a resident of that State. Where, however, In case the person paying payer of the royalties, whether he is a resident of a Contracting State or not, however, has in a Contracting State a permanent establishment or a fixed base in connection with a Contracting State which as such incurs the right or property giving rise to the royalties is effectively connectedcharge thereof, and such these royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner of the royalties or between both of them and some other person, the amount of the royalties, having regard to the use, right or information service for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 7. The provisions of this Article shall no apply if the purpose or one of the main purposes of any person involved in the creation or attribution of rights in connection with which the royalties are paid is to take advantage of this Article through such creation or attribution.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. 3. Notwithstanding the provisions of paragraph 2, copyright royalties and other like payments in respect of the production or reproduction of any literary, dramatic, musical or other artistic work (3but not including royalties in respect of motion picture films nor royalties in respect of works on film or videotape or other means of reproduction for use in connection with television broadcasting) arising in a Contracting State and paid to a resident of the other Contracting State, who is the beneficial owner of the royalties, shall be taxable only in that other State. 4. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literarycopyright, artistic or scientific work including cinematograph films and recordings for radio and television, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, process or for information concerning industrial, commercial or scientific experienceother intangible property, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience, and includes payments of any kind in respect of motion picture films and works on film, videotape or other means of reproduction for use in connection with television. (4) 5. The provisions of paragraphs 1 1, 2 and 2 3 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) 6. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy or a resident of that State. Where, however, the person paying the royalties, whether he the payer is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) 7. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other another person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which that would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 15 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and recordings or tapes used for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concer ning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with with: (a) such permanent establishment or fixed base, or (b) business activities referred to under (c) of paragraph 1 of Article 7. In such case cases the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 7. The provisions of this Article shall likewise apply to gains from the alienation of any right or property giving rise to such royalties if such right or property is alienated by a resident of a Contracting State for exclusive use in the other Contracting State and the payment for such right or property is borne by an enterprise of that other State or by a permanent establishment situated therein.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent 5% of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph cinematography films and recordings films or tapes used for radio and or television, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case royalties may be, shall applybe taxed in that other State according to its own laws. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political or administrative subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise to contract under which the royalties is effectively connectedare paid was concluded, and such royalties are borne by such permanent establishment or fixed baseit, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 15 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and recordings or tapes used for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case cases the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, political subdivision or a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise obligation to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings films or tapes for radio and televisionor televsion broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business bussiness in the other Contracting State in which the royalties arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political or administrative subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due dur regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws law of that State, ; but if the beneficial owner of the royalties is a resident of the other Contracting StateState is the beneficial owner of the royalties, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literarycopyright, artistic or scientific work including cinematograph films and recordings for radio and television, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience, and includes payments of any kind in respect of motion picture films and works on film or videotape for use in connection with television. (4) . The provisions of paragraphs 1 and paragraph 2 shall not apply if the beneficial owner recipient of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, or performs in that other State independent personal professional services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise obligation to pay the royalties is effectively connectedwas incurred, and such those royalties are borne by such that permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may shall be taxed taxable in that other Contracting State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent 5% of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films cinematographic films, or films, tapes and recordings for radio and televisionother means of image or sound reproduction, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, experience or for the use of, or the right to use, industrial, commercial or scientific equipment. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated thereinbase, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise to the royalties is effectively connected, and such royalties are borne by such permanent establishment establishment, or fixed base, base then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right to use or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such a relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, with due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed only in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and recordings films, tapes or disks for radio and television, or television broadcasting) any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for the use of or the right to use industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy authority or a or a [sic] resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise to in respect of which the royalties are paid is effectively connected, connected and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) Where, . Where by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State one of the two States and paid to a resident of the other Contracting State may be taxed in that other StateStates. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments payment of any kind received as a consideration for the use of, or the right to use, any copyright of literaryliterati, artistic or scientific work - including cinematograph films and recordings films or tapes used for radio and television, or television broadcasting - any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. however, or the term does not include payment for the use of, or the right to use, industrial, commercial or scientific equipmentfurnishing of technical services. (4) . The competent authorities of the two States shall by mutual agreement settle the mode of application of paragraphs 2. 5. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner recipient of the royalties, being a resident of a Contracting Stateone of the two States, carries on business has in the other Contracting State States in which the royalties arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and with which the right or property in respect of which giving rise to the royalties are paid is effectively connected with such permanent establishment or fixed baseconnected. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) 6. Royalties shall be deemed to arise in a Contracting State one of the States when the payer is that State States itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. State Where, however, the person paying the royalties, whether he is a resident of a Contracting State one of the two States or not, has in a Contracting State one of the two States a permanent establishment or a fixed base in connection with which the right or property giving rise to the contract under which royalties is effectively connectedare paid was concluded, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) 7. Where, by reason of owing to a special relationship between the payer and the beneficial owner recipient or between both of them and some other person, the amount of the royaltiesroyalties paid, having regard regarding to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-last - mentioned amount. In such that case, the excess part of the payments payment shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent of the gross amount of the such royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and recordings or tapes used for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipmentequipment or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, or a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Statesuch royalties, the tax so charged shall not exceed 10 per cent 10% of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including computer programs, cinematograph films, and films and recordings or tapes for television or radio and televisionbroadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 7. The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the royalties are paid to take advantage of this Article by means of that creation or assignment.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties referred to in paragraph 1 of this Article may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent percent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings for radio and televisioncinematography films, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions provision of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions provision of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 5 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literarycopyright, artistic or scientific work including cinematograph cinematographic films and films and recordings for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may shall be taxed taxable only in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings films and tapes recorded for radio and broadcasting or television, any patent, know-how, trade mark, design or model, model plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 1413, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itself, a policitical subdivision, a local authoritiy authority or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise obligation to pay the royalties is effectively connectedwas incurred, and such those royalties are borne by such that permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 15 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph cinematography films, or films and recordings or tapes for radio and televisionor television broadcasting, any patent, trade marktrademark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right right, property or property contract in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itself, a policitical subdivisionContracting State, a local authoritiy authority thereof or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 15 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work work, including cinematograph films and recordings or films or tapes used for radio and televisionradio, or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 1413, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivisionpolitical sub-division, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph cinematography films, or films and recordings or tapes for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itself, a policitical subdivisionContracting State, a local authoritiy authority thereof or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 5 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings for radio and televisionfilms, any software, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, for the use of, or the right to use industrial, commercial or scientific equipment or transport vehicles, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, of this Agreement shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 exceed: (a) 12.5 per cent of the gross amount of the royalties, if the royalties consist of payments of any kind received as a consideration for the use of, or the right to use, any patent, trademark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, cinematograph films or tapes for television or broadcasting; (b) 15 per cent of the gross amount of the royalties, if the royalties consist of payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph film or films and recordings or tapes for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base, or with other business activities connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 1415, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivisionan administrative-territorial unit, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including computer software, other records on information-carrying mediums, cinematograph films and recordings films, tapes or discs for radio and televisionor television broadcasting), any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial commercial or scientific equipment or for information concerning industrial, commercial or scientific equipmentexperience. (3. However, such royalties may also be taxed in the Contracting State in which they arise and in accordance with the laws of that Contracting State, but if the beneficial owner of the royalties is the resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 4) . Notwithstanding the provisions of paragraph 3, in the case of payment of royalties in respect of any copyright of scientific work, any patent, trade mark, secret formula, process or information concerning industrial, commercial or scientific experience the tax charged shall not exceed 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 5. The provisions of paragraphs 1 1, 2, 3 and 2 4 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that the other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) 6. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) 7. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.Agreement.‌

Royalties. (1) . Royalties arising in derived from a resident of a Contracting State and paid to by a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws law of that State, but if the beneficial owner of the royalties is a resident of subject to tax thereon in the other Contracting State, the tax so charged shall not exceed 10 12.5 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings films or tapes used for radio and televisiontelevision broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 of this Article shall not apply if where the beneficial owner of the royalties, being a resident of a one of the Contracting StateStates, carries on business has in the other Contracting State in which the royalties arise through a permanent establishment situated thereinestablishment, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with the business carried on through such permanent establishment or fixed base. In such a case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise obligation to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 7. The provisions of this Article shall not apply if the right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent 15 percent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and recordings or tapes used for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case cases the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 15 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and recordings films, tapes or discs for radio and televisionor television broadcasting), any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned last -mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the such royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and recordings or tapes used for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with (a) such permanent establishment or fixed base, or with (b) business activities referred to under (c) of paragraph 1 of Article 7. In such case cases the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, or a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may shall be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, ; but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literarycopyright, artistic or scientific work including cinematograph films and recordings for radio and television, any patent, trade marktrademark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience; this term also includes payments of any kind for cinematographic films and works recorded on film and tape for television broadcasting. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal professional services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case cases the provisions of Article 7 article VII or Article 14article XV, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a territorial administrative subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise to contract under which the royalties is effectively connectedare paid was concluded, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner recipient or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner recipient in the absence of such relationship, the provisions of this Article article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings films or tapes for radio and televisionor television broadcasting, any patent, know-how, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy authority or a resident of that the State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State one of the two States and paid to a resident of the other Contracting State may be taxed in that other StateStates. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments payment of any kind received as a consideration for the use of, or the right to use, any copyright of literaryliterati, artistic or scientific work - including cinematograph films and recordings films or tapes used for radio and television, or television broadcasting - any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. however, or the term does not include payment for the use of, or the right to use, industrial, commercial or scientific equipmentfurnishing of technical services. (4) . The competent authorities of the two States shall by mutual agreement settle the mode of application of paragraphs 2. 5. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner recipient of the royalties, being a resident of a Contracting Stateone of the two States, carries on business has in the other Contracting State States in which the royalties arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and with which the right or property in respect of which giving rise to the royalties are paid is effectively connected with such permanent establishment or fixed baseconnected. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) 6. Royalties shall be deemed to arise in a Contracting State one of the States when the payer is that State States itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. State Where, however, the person paying the royalties, whether he is a resident of a Contracting State one of the two States or not, has in a Contracting State one of the two States a permanent establishment or a fixed base in connection with which the right or property giving rise to the contract under which royalties is effectively connectedare paid was concluded, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph cinematography films, or films and recordings or tapes for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itself, a policitical subdivisionContracting State, a local authoritiy authority thereof or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that Contracting State, but if the beneficial owner of the royalties is a resident of the other Contracting State, State the tax so charged shall not exceed 10 ten per cent of the gross amount of the such royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including inclUding cinematograph films and recordings works on films, tapes or other means of reproduction for use in connection with television or radio and televisionbroadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information (know-how) concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated thereinin that other Contracting State, or performs in that other Contracting State independent personal services from a fixed base situated thereinin that Contracting State, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy or a resident of that Contracting State. Where, however, the person paying the royalties, whether he that person is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise to in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) Where. STAATSKOERANT, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.20 APRIL 2007 No.29815 23

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent percent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments payments, of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and recordings or tapes used for radio and televisionor television broadcasting, any patent, trade mark, ▇▇▇▇ design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipmentequipment or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base base, situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise to the royalties is effectively connected, and such royalties are borne by such permanent establishment establishment, or fixed base, base then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royaltiesroyalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such a relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each each- Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings films or tapes for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itself, a policitical subdivisionContracting State, a local authoritiy authority thereof or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of the each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "royalties" royalties " as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and recordings or tapes used for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 1415, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivisionpolitical sub-division, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings films or tapes for radio and televisionor television broadcasting, any patent, trade mark, know how, design or model, computer programme, plan, secret formula or process, or for the use of or the right to use industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment. (4) The provisions of paragraphs 1 1) and 2 2), shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then then, such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) Where, Where by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that Statestate, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so to charged shall not exceed 10 15 per cent of the gross amount of the royalties. (3) . The term "royalties" royalties " as used in this Article means payments of any kind received as a consideration for the use ofuse, or the right to use, any copyright of literary, artistic or scientific work work, including cinematograph films, or films and recordings or tapes used for the radio and television, or television broadcasting any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of cf Article 7 or Article 1413, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivisionpolitical sub-division, a local authoritiy authority or a resident of that State. Where, however, however the person paying the royalties, whether whether, he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or of fixed base, then such royalties shall be deemed deemd to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, royalties having regard ▇▇▇▇▇▇ to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 5 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including software and cinematograph films and recordings for radio and televisionfilms, any patent, trade mark▇▇▇▇, drawing, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment or for information concerning industrial commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such the permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings films or tapes for radio and broadcasting or television, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itself, a policitical subdivision, a local authoritiy authority or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise obligation to pay the royalties is effectively connectedwas incurred, and such those royalties are borne by such that permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the a other Contracting State may be taxed in that other Contracting State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise it arises and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, interest the tax so charged shall not exceed 10 per cent percent of the gross amount of the royaltiesroyalty. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work work, including cinematograph films and recordings films, films, tapes or disc for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royaltiesroyalty, being a resident of a Contracting State, carries on business industrial or commercial activity in the other Contracting State in which the royalties arise royalty arises, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are royalty is paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 1413, as the case may be, shall apply. (5) Royalties . Royalty shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivisionpolitical sub division, a local authoritiy authority or a resident of that State. Where, however, the person paying the royaltiesroyalty, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise to indebtedness on which the royalties royalty is effectively connectedpaid was incurred, and such royalties are royalty is borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or a fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personpersons, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent 18 percent of the gross amount of the royaltiesroyalties referred to in paragraph 3 of this Article. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of these limitations. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings films, or tapes for television or radio and televisionbroadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or processany industrial or scientific equipment, or for information concerning industrial, commercial industrial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that Contracting State itself, a policitical subdivision, a local authoritiy authority or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent of the gross amount of the such royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and recordings or tapes used for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipmentequipment or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, or a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 3[ 10 per cent cent] of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind kind, received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work work, including cinematograph films, or films and recordings or tapes used for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply apply, if the beneficial owner of the royalties, royalties being a resident of a Contracting State, State carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case a case, the provisions of Article 7 or Article 1415, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivisionpolitical sub-division, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, royalties whether he is a resident of a Contracting State or not, not has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information information, for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments payment shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 3. Substituted for "15 per cent" by Notification ▇▇.▇▇ 2689(E), dated 7-11-2012.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 15 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments payment of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings films, or tapes for radio and televisiontelevision or broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 of this Article, shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with (a) such permanent establishment or fixed base, or with (b) business activities referred to under (c) of paragraph 1 of Article 7. In such case cases, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, royalties paid having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 15 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings or tapes for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for the use of or the right to use industrial, commercial or scientific equipment involving a transfer of know-how or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment. (4) . The provisions of paragraphs 1 (1) and 2 (2) shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or of Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then then, such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) Where, . Where by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person,, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 7. Notwithstanding the provision in paragraph (2) of a rate of tax of 15 per cent, where in any future Convention for the avoidance of double taxation and the prevention of fiscal evasion entered into by the first- mentioned Contracting State with any other State (not being the other Contracting State in the present Convention) the rate of tax specified in the Article relating to royalties is a rate less than 15 per cent, such lower rate shall apply as if it had been the rate specified in this Article.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 8 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic artistic, or scientific work including cinematograph cinematography films and recordings (or films or tapes used for radio and televisionor television broadcasting), any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 (Business Profits) or Article 1414 (Independent Personal Services), as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political or administrative-territorial subdivision, a local authoritiy authority, or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable in the Contracting State in which the royalties arise, according to the laws of each Contracting that State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) Howevershall, such royalties may also be taxed in if the Contracting State in which they arise and according to the laws of that State, but if recipient is the beneficial owner of the royalties is a resident of royalties, be taxable only in the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) 2. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and recordings films, tapes or discs for radio and televisionor television broadcasting), any patent, trade mark, design or model, computer programme, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, use industrial, commercial or scientific equipmentequipment or for information concerning industrial, commercial or scientific experience. (4) 3. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise to in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royaltiesroyalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings for radio and television, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment. (4) The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise to the royalties is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising from sources in a Contracting State which are derived and paid to beneficially owned by a resident of the other Contracting State may shall be taxed taxable only in that other State. (2) However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ”, as used in this Article Article, means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and motion pictures or films, recordings on tape or other media used for radio and televisionor television broadcasting or other means of reproduction or transmission), any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrialor, commercial or scientific experiencesubject to the provisions of paragraph 2 of Article 8 (Shipping and Air Transport), or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) 3. The provisions of paragraphs paragraph 1 and 2 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 (Business Profits) or Article 14, as the case may be, 14 (Independent Personal Services) shall apply. (5) 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise obligation to pay the royalties is effectively connectedwas incurred, and such the royalties are borne by such that permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royaltiesroyalties paid, having regard to the use, right or information for which they are paid, exceeds exceeds, for whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.only

Royalties. (1) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties and is a resident subject to tax in respect of the royalties in that other Contracting State, State the tax so charged shall not exceed 10 12.5 per cent of the gross amount of the royalties., (3) The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (but not including cinematograph films, and films and recordings or tapes for radio and televisionor television broadcasting), any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information (know-how) concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment. (4) The provisions of paragraphs 1 (1) and 2 (2) of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise State, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 1414 of this Convention, as the case may be, shall apply. (5) Royalties shall be deemed to arise in a Contracting State when where the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise obligation to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royaltiesroyalties paid exceeds, having regard to the usefor whatever reason, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. (7) The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the right or property in respect of which the royalties are paid to take advantage of this Article by means of that creation or assignment. (8) For the purposes of paragraph (2) of this Article, if the beneficial owner of the royalties is a body of persons or trust established for charitable purposes only and is a resident of one of the Contracting States, that body of persons or trust shall be deemed to be subject to tax in that State in respect of those royalties.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 ten per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph cinematography films, or films and recordings or tapes for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as 14,as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itself, a policitical subdivisionContracting State, a local authoritiy authority thereof or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-last mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent 7.5% of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph cinematography films, or films and recordings or tapes for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itself, a policitical subdivisionContracting State, a local authoritiy authority thereof or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . The provisions of this Article shall not apply if the right giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bonafide commercial reasons. 7. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent 15 percent of the gross amount of the royalties. (3) . The term "royalties" ", as used in this Article means payments of any kind received as a consideration for the use of, or the right r ight to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and recordings or tapes for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise obligation to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personpersons, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount amo unt which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws of that Contracting State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent 10% of the gross amount of the royalties. (3) The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, films and recordings or tapes or other means for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipmentexperience (know-how). (4) The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or of property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy authority thereof or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated.such (6) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent percent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and recordings or tapes for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall shall, not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In In' such case cases the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itselfState, a policitical political subdivision, a local authoritiy authority thereof or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for for: the use of, or the right to use, any copyright of literarycopyright, artistic or scientific work including cinematograph films and recordings for radio and television, any patent, trade marktrademark, design or model, plan, secret formula or process, or for information concerning industrial, commercial other like property or scientific experienceright; the use of, or the right to use: motion picture films; films or audio or video tapes or disks, or any other means of image or sound reproduction or transmission for use in connection with television, radio, internet or other broadcasting; the use of, or the right to use, any industrial, scientific or commercial equipment; knowledge or information concerning industrial, technical, commercial or scientific equipment. (4experience; any assistance that is ancillary and subsidiary to, and is furnished as a means of enabling the application or enjoyment of, any such property or right as is mentioned in subparagraph a) or b), any such equipment as is mentioned in subparagraph c) or any such knowledge or information as is mentioned in subparagraph d); giving up, wholly or partly, a right relating to the use or supply of any property or right referred to in this paragraph. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy or a resident of that Contracting State. Where, however, the person paying the royalties, whether he the person is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by by, or deductible in determining the profits attributed to, such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws law of that State, but but, if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 exceed: a) in the case of the Philippines, 15 per cent of the gross amount of the royalties, where the royalties are paid by an enterprise registered with the Philippine Board of Investments and engaged in preferred areas of activities and also royalties in respect of cinematographic films or tapes for television or broadcasting; b) in all other cases, 25 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work work, including cinematograph films and recordings films, or tapes for radio and televisiontelevision or broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner recipient of the royalties, being a resident of a Contracting State, carries on business “in the other Contracting State in which the royalties arise arise,” through a permanent establishment situated therein, or performs in that other State independent personal professional services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case a case, the provisions of Article 7 or Article 14, as the case may be, shall applyroyalties are taxable in that other Contracting State according to its own law. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political or administrative subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise to contract under which the royalties is effectively connectedare paid was concluded, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, and films and recordings or tapes for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such a)such permanent establishment or fixed base, or b)business activities referred to in paragraph 2 of Article 7. In such case a case, the provisions of Article 7 or Article 1415, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 5 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind kind, including payments in kind, received as a consideration for the use of, or the right to use, any copyright of literary, literary artistic or scientific work work, including cinematograph films, and films and recordings or tapes for radio and or television, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed basethe 5. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivisionlocal authority, a local authoritiy an administrative-territorial unit or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.absence

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings films or tapes for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that Contracting State itself, a policitical political subdivision, a local authoritiy authority or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings or tapes for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivisionPolitical sub-division, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments royalties shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films films, and recordings films, discs or tapes for radio and televisionor television broadcasting, any patent, patent trade mark, design or model, plan, plan secret formula or process, or for the use of, or right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 12.5 per cent of the gross amount of the royalties. (3) . The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings or films or tapes used for radio and televisionor television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, base then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Stateroyalties, the tax so charged shall not exceed 10 15 per cent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph cinematography films, or films and recordings or tapes used for radio and televisionor television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific equipmentexperience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case cases the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, political subdivision or a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise obligation to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may shall be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, then the tax so charged shall not exceed 10 per cent 3% (three percent) of the gross amount of the such royalties. (3) The term "royalties" as used . Notwithstanding the provisions of paragraph 2, approved industrial royalties shall be exempted from tax in either Contracting State. 4. In this Article the term “royalties” means payments payment of any kind received as consideration for: the copy right (other than a consideration for the use of, or the right to use, any copyright of literary, dramatic, musical or artistic or scientific work including cinematograph films and recordings for radio and televisioncopy right), any patent, trade mark, design or model, plan, plan or secret formula or process, process trade ▇▇▇▇ or for information concerning industrial, commercial or and scientific experience, but does not include payment in respect of the operation of mines or for the use of, quarries or the right to use, industrial, commercial or scientific equipmentexploitation of natural resources. (4) 5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, State carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, located therein or performs in that other State state independent personal services from a fixed base situated therein, therein and the right or of property in respect of which the royalties are paid is effectively directly connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, 15 as the case may be, be shall apply. (5) 6. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical political subdivision, a local authoritiy authority or administrative territorial units, thereof or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise liability to pay the royalties is effectively connectedwas incurred, and such royalties are borne by such permanent establishment establishment, or a fixed base, base then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or a fixed base is situated. (6) 7. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had given to the other provisions of this Agreementagreement.

Royalties. (1) . Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2) . However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent 8 percent of the gross amount of the royalties. (3) . The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films,or films and recordings or tapes for radio and television, or television broadcasting ,any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a policitical subdivision, a local authoritiy authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property giving rise to the royalties is effectively connected, and such royalties are borne by such permanent establishment establishment, or fixed base, base then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.