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, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or models, plan, secret formula or process, 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 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, a local 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 liability to pay the royalties was 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 exceed: (a) 10 per cent of the gross amount of the royaltiesroyalties referred to in paragraph 3 (a) ; (b) 15 per cent of the gross amount of the royalties referred to in paragraph 3 (b) . 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for: (a) the use of, or the right to use, any patent, know-how, trade mark, design or model, plan, secret formula or process, copyright of any scientific work, or for the use of, or the right to use, any copyright of literaryindustrial, artistic commercial, or scientific work, including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or models, plan, secret formula or processequipment, or for information concerning industrial, commercial or scientific experience; (b) the use of, or the right to use any copyright of literary or artistic work including cinematograph films, or tapes for radio or television broadcasting. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 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 the Government of that State, a political subdivision, a local authority thereof 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 liability to pay the royalties was incurred, and such royalties are borne brone 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. 7. Royalties derived by a resident of China which are subjected to film hire duty under the Cinematograph Film-Hire Duty Act in Malaysia shall not be liable to Malaysian tax to which this Agreement applies.

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 only 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 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, work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, or secret formula or process, or for information concerning industrial, commercial or scientific experience. 43. The provisions of paragraphs paragraph 1 and 2 of this Article shall not apply if the beneficial owner of the royalties 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 Convention shall apply. 54. Royalties shall be deemed to arise in a Contracting State when the payer is that State, a local 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 liability to pay the royalties was incurred, 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. 65. 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 beneficially owned 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 and according to the laws of in 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, work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, 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 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, 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, a local authority thereof 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 liability obligation to pay the royalties was 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 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 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, work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, 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 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, 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, a local 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 liability to pay the royalties was incurred, 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 law 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 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 for: (a) the use of, or the right to use, any copyright of literary, artistic or scientific work, including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience; (b) the use of, or the right to use, cinematograph films, or tapes for radio or television broadcasting, any copyright of literary or artistic work. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 baseestablishment. 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 StateState itself, a political subdivision, a local authority thereof or a statutory body thereof, or a resident of that State. Where, however, the person paying the such 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 liability obligation to pay the royalties was 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, 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 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 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 7.5 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, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, 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. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 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, a local 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 liability to pay the royalties was 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 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 for: (a) the use of, or the right to use, any copyright of literary, artistic or scientific work, including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience; (b) the use of, or the right to use, cinematograph films, or tapes for radio or television broadcasting, any copyright of literary or artistic work. 4. The provisions of paragraphs 1 and 2 shall not apply if of the beneficial owner of the royalties 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 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 StateState itself, a political subdivision, a local authority thereof or a statutory body thereof, or a resident of that State. Where, however, the person paying the such 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 liability obligation to pay the royalties was 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 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 beneficially owned by a resident of the other Contracting State may be taxed in that other State. (2. ) However, such the royalties referred to in paragraph 1 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 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, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or for the use of, or the right to use any 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 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, a local 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 liability to pay the royalties was 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 workwork including computer software, including cinematograph films, or films films, tapes or tapes discs used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, 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 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 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, a local 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 liability to pay the royalties was 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 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, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, or secret formula or process, 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 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, a local 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 liability to pay the royalties was incurred, 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 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 fifteen 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: (a) the use of, or the right to use, any copyright of literary, artistic or scientific work, including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or any copyright or scientific work, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience; (b) the use of, or the right to use, cinematograph films, or tapes for radio or television broadcasting, any copyright of literary or artistic work. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 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 StateState itself, a political subdivision, a local authority thereof or a statutory body thereof, or a resident of that State. Where, however, the person paying the such 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 liability obligation to pay the royalties was 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 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 One Side and paid to a resident of the other Contracting State Other Side may be taxed in that other StateOther Side. 2. However, such royalties may also be taxed in the Contracting State Side in which they arise and according to the laws of that StateSide, but if the beneficial owner of the royalties is a resident of the other Contracting StateOther Side, the tax so charged shall not exceed 10 per cent 7% of the gross amount of the royalties. The competent authorities of both Sides 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 the copyright of literary, artistic or scientific work, works including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇trademark, design or modelsmodel, 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. 4. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the royalties royalties, being the Government of One Side, a local authority thereof or a resident of a Contracting Statethat Side, carries on business in the other Contracting State Other Side 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 that 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 One Side when the payer is the Government of that StateSide, a local authority thereof or a resident of that StateSide. WhereHowever, however, where the person paying the royalties, whether he is the Government of One Side, a local authority thereof or a resident of a Contracting State that Side or not, has in a Contracting State that Side a permanent establishment or a fixed base in connection with which the liability to pay the royalties was incurred, and such royalties are borne by such that permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the State Side 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 exceeds, having regard to the usefor whatever reasons, 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 StateSide, but due regard being shall still be had to the other provisions of this AgreementArrangement.

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, work (including cinematograph films, or and films or tapes used for radio or television broadcasting), any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or other like right or property, or for information (know-how) concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 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, a local 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 liability to pay the royalties was incurred, 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 of the royalties 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 of the royalties 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. No relief shall be available under this Article 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 beneficially owned by a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties arising in a Contracting State may also be taxed in the Contracting that 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, work including software and cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or for information (know-how) 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 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, 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 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, a local 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 liability to pay the royalties was 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 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 Agreement. 6. No relief shall be available under this Article 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 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 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. 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 or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or for information (know-how) concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 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, a local authority thereof or a resident of that 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 liability to pay right or property in respect of which the royalties was incurredare paid is effectively connected, 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 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 Agreement. 7. No relief shall be available under this Article 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 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 12 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 or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experienceexperience and any copyright of literary or artistic work. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise a business 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 baseservices. 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 StateContracting State itself, a political subdivision, a local 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 liability obligation to pay the royalties was 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 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 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. 7. Royalties derived by a resident of the Czech Republic, being royalties that, as film rentals, are subject to the cinematograph film-hire duty in Malaysia, shall not be liable to Malaysian tax.

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 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, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, or secret formula or process, 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 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, a local 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 liability to pay the royalties was incurred, 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 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, work (including cinematograph cinematographic films and films, tapes and other means of image or films or tapes used for radio or television broadcasting, sound reproduction) any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or processprocess or other 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. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 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, a local 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 liability obligation to pay the royalties was 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 royaltiesroyalties 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 Agreement. 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 to 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 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 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, work including cinematograph films and works on films, tapes or films other means of reproduction for use in connection with television or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or for information (know-how) concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the royalties 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 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 1414 of this Agreeement , as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State, a local 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 liability to pay the royalties was 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 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 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, work (including cinematograph films and films, tapes or films or tapes used discs for radio or television broadcasting), any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, 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 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 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, a local 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 liability to pay the royalties was 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 Stateroyalties, the tax so charged shall not exceed 10 exceed: (a) in the case of Laos: -5 per cent of the gross amount of the royalties; (b) in the case of China: -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 the above 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, work including cinematograph films, films or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, 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. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 the Government of that Contracting State, a local 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 liability to pay the royalties was 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, 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 workwork including software, including cinematograph films, or films and films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, or secret formula or process, or for information concerning industrial, commercial or scientific experienceexperi- ence. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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, situat- ed therein and the right or property in respect of which the royalties are paid is effectively effec- tively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article Ar- ticle 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, a local 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 per- manent establishment or a fixed base in connection with which the liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties ▇▇▇- alties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base estab- lishment 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 Party and paid to a resident of the other Contracting State Party may be taxed in that other StateParty. 2. However, such royalties may also be taxed in the Contracting State Party in which they arise and according to the laws of that StateParty, but if the beneficial owner of the royalties is a resident of the other Contracting StateParty, the tax so charged shall not exceed 10 3 per cent of the gross amount of the royalties. The competent authorities of the Contracting Parties 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, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, 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 royalties, being a resident of a Contracting StateParty, carries on business in the other Contracting State Party 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 Party when the payer is that State, a local authority thereof or a resident of that StateParty. Where, however, the person paying the royalties, whether he is a resident of a Contracting State Party or not, has in a Contracting State Party a permanent establishment or a fixed base in connection with which the liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the State Party 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 StateParty, 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 only in that other State. 2. However, State if such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if resident 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. 32. 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 or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 43. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties 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, a local 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 liability to pay the royalties was 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. 64. 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. 5. Royalties shall be deemed to arise in a Contracting State when the payer is the State itself, a political subdivision, a local 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 liability to pay the royalties was 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.

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, work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, 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 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 StateState itself, a political subdivision, a local 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 liability to pay the royalties was 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 5 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 and films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, 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 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, 14 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State, a local 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 liability obligation to pay the royalties was 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 the 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, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, 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 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 where the payer is that State, a local 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 liability to pay the royalties was incurred, incurred 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 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 beneficial owner of the royalties is a resident of the other Contracting State, then 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, use any copyright copy right of literary, artistic artistic, or scientific work, work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, 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. 4. The provisions of paragraphs 1 and 2 shall not 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, therein or performs in that other 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 or with: (a) such permanent establishment or fixed base; or with (b) business activities referred to under (c) or paragraph 1 of Article 7. 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 StateState itself, a political subdivision, a local 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 liability to pay the royalties was incurred, 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 given to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State Party and paid to a resident of the other Contracting State Party may be taxed in that other StateContracting Party. 2. However, such royalties arising in a Contracting Party may also be taxed in the that Contracting State in which they arise and Party according to the laws of that StateContracting Party, but if the beneficial owner of the royalties is a resident of the other Contracting StateParty, 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, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, 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 royalties, being a resident of a Contracting StateParty, carries on business in the other Contracting State Party 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 Party when the payer is that State, a local authority thereof or a resident of that StateParty. Where, however, the person paying the royalties, whether he is a resident of a Contracting State Party or not, has in a Contracting State Party a permanent establishment or a fixed base in connection with which the liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the State Party 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 StateParty, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State Party and paid to a resident of the other Contracting State Party may be taxed in that other StateParty. 2. However, such royalties may also be taxed in the Contracting State Party in which they arise and according to the laws of that StateParty, but if the beneficial owner of the royalties is a resident of the other Contracting StateParty, the tax so charged shall not exceed 10 3 per cent of the gross amount of the royalties. The competent authorities of the Contracting Parties 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, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, 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 royalties, being a resident of a Contracting StateParty, carries on business in the other Contracting State Party 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 Party when the payer is that State, a local authority thereof or a resident of that StateParty. Where, however, the person paying the royalties, whether he is a resident of a Contracting State Party or not, has in a Contracting State Party a permanent establishment or a fixed base in connection with which the liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the State Party 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 exceeds, having regard to the usefor whatever reasons, 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 StateParty, 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 films, films or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇trademark, design or modelsmodel, plan, secret formula or process, 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 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 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 StateState itself, a political subdivision, a local authority thereof 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, has in a Contracting State a permanent establishment or a fixed base in connection with which the liability to pay the royalties was incurred, and such royalties 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 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 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 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, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, or secret formula or process, 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 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, a local 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 liability to pay the royalties was incurred, 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 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, work including cinematograph films, films or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, 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 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 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, a local 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 liability to pay the royalties was incurred, 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 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 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, work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or processprocess or breeder’s right of new varieties of plants, 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 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 State, a local 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 liability to pay the royalties was 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 which are derived and paid to beneficially owned 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 and according to the laws law 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, work (including cinematograph films, or and films or tapes used for radio or television broadcasting), any patent, trade ▇▇▇▇, design or modelsmodel, 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. (4. ) The provisions of paragraphs 1 (1) and 2 (2) of this Article shall not apply if the beneficial owner of the royalties royalties, being a resident of a Contracting State, carries on business has in the other Contracting State in which the royalties arise, through arise 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 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 where the payer is that StateState itself, a political subdivision, a local authority thereof or a resident of that State. Where. (6) Notwithstanding the provisions of paragraph (5) of this Article, however, where the person paying payer of 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 liability to pay the royalties was incurredincurred and which bears the royalties, and such royalties are borne by such permanent establishment or fixed base, then such the royalties shall be deemed to arise in the Contracting 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 person deriving the royalties 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 paid 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 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 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, work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, 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 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, 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, a local 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 liability to pay the royalties was incurred, 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 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: (a) he use of, or the right to use, any patent, trade mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, any copyright of literaryindustrial, artistic commercial, or scientific work, including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or models, plan, secret formula or processequipment, or for information concerning industrial, commercial or scientific experience; (b) the use of, or the right to use, cinematograph films, or tapes for radio or television broadcasting, any copyright of literary or artistic work. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 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 StateState itself, a political subdivision, a local authority thereof or a statutory body thereof, or a resident of that State. Where, however, the person paying the such 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 liability obligation to pay the royalties was 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 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 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. (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, films or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, 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 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, a local 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 liability to pay indebtedness on which the royalties are paid was 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 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 7.5 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, tapes or films or tapes used discs for radio or television broadcasting), any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, or for information (know-how) 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 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 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, a local 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 liability to pay the royalties was 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 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 Agreement. 6. Royalties shall be deemed to arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the royalties, whether that person is a resident of a Contracting State or not, has in a Contracting State a permanent establishment with which the right or property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment is situated. 7. No relief shall be available under this Article 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 the first-mentioned 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 The tax so charged shall not exceed 10 per cent (5) five percent of the gross amount of the royalties. 32. The term “royalties” as used in this Article means 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 or tapes used for radio or television broadcastingand computer software, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula 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 experienceexperience (know-how). 43. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties 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 case, the provisions of Article 7 or Article 14and 14 shall apply, as the case may be, shall apply. 54. Royalties shall be deemed to arise in a Contracting State when the payer is that State, a local 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 liability to pay the royalties was 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. 65. 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 territory and paid to a resident of the other Contracting State territory may be taxed in that other Stateterritory. 2. However, such royalties may also be taxed in the Contracting State territory in which they arise and according to the laws of in force in that Stateterritory, but if the beneficial owner of the royalties is a resident of the other Contracting Stateterritory, 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, work including cinematograph films, or films and films or tapes used for television or radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, 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 royalties, being a resident of a Contracting Stateterritory, carries on business in the other Contracting State territory in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other State territory 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 territory when the payer is that State, a local authority thereof or a resident of that Stateterritory. Where, however, the person paying the royalties, whether he is a resident of a Contracting State territory or not, has in a Contracting State territory a permanent establishment or a fixed base in connection with which the liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State territory 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 in force in each Contracting Stateterritory, 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, work including cinematograph films, or and films or tapes used for radio or television broadcasting, any patent, computer software, trade ▇▇▇▇, design or modelsmodel, 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. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 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, a local 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 liability to pay the royalties was incurred, 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 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 for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner of the royalties 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 the royalties referred to in paragraph 1 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, work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or for the use of, or the right to use, any 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 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 baseestablishment. 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, a local 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 liability to pay the royalties was 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 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, work including cinematograph films, or films or tapes used and recordings for radio or television broadcastingand television, any patent, trade ▇▇▇▇, design or modelsmodel, 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 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 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 StateState itself, a political subdivision, a local authority thereof or a statutory body 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 liability right or property giving rise to pay the royalties was incurredis effectively connected, 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 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 amount in such case, 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 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: (a) the use of, or the right to use, any copyright of literary, artistic or scientific work, including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or any copyright of scientific work or for the use of, or the right to use, industrial, commercial or scientific equipment, or for the information concerning industrial, commercial or scientific experience; (b) the use of, or the right to use, cinematograph films, films or tapes for radio or television broadcasting, any copyright of literary or artistic work. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 baseestablishment. 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 StateState itself, an administrative subdivision, a local authority thereof or statutory body thereof, or a resident of that State. Where, however, the person paying the such 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 liability to pay the royalties was 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 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 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. 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 cinematography films, or films or tapes used for radio or television broadcasting, any patent, software, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, 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 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, a local 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 liability to pay the royalties was 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 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 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, or films and films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, 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. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 baseestablishment. 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 StateState itself, a political subdivision, a local authority thereof or a statutory body thereof, or a resident of that State. Where, however, the person paying the royalties, whether he or she 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 liability to pay the royalties was 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, 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 the 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's 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: (a) the use of, or the right to use, any patent, trade mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, any copyright of literaryindustrial, artistic commercial, or scientific work, including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or models, plan, secret formula or processequipment, or for information concerning industrial, commercial or scientific experience; (b) the use of, or the right to use, cinematograph films, or tapes for radio or television broadcasting, any copyright of literary or artistic work. 4. The provisions of paragraphs 1 (1) and 2 (2) shall not apply if the beneficial owner of the royalties 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 a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise rise in a Contracting State when the payer is that StateState itself, a political subdivision, a local authority thereof or a statutory body thereof, or a resident of that State. Where, however, the person paying the such 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 liability obligation to pay the royalties was 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 royaltiesroyalties paid, having regard to the use, right or of 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 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 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, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, or secret formula or process, 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 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, a local 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 liability to pay the royalties was incurred, 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 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 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 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, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, or secret formula or process, 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 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, a local 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 liability to pay the royalties was incurred, 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 AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State Party and paid to a resident of the other Contracting State Party may be taxed in that other StateContracting Party. 2. However, such royalties may also be taxed in the Contracting State Party in which they arise and according to the laws of that StateContracting Party, but if the beneficial owner of the royalties is a resident of the other Contracting StateParty, 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, or films and films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, or secret formula or process, 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 royalties, being a resident of a Contracting StateParty, carries on business in the other Contracting State Party 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 Party when the payer is that State, a local authority thereof or a resident of that StateContracting Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting State Party or not, has in a Contracting State Party a permanent establishment or a fixed base in connection with which the liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the State Contracting Party 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 StateParty, 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, work including cinematograph films, or films or tapes used and recordings for radio or television broadcasting, any patent, know-how, trade ▇▇▇▇, design or modelsmodel, 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 commercial, or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 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 the Government of that Contracting State, a political subdivision, a local 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 liability to pay the royalties was 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 beneficially owned by a resident of the other Contracting State may be taxed in that other State. (2. ) However, such the royalties referred to in paragraph 1 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 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, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, or for the use of, or the right to use any 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 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, a local 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 liability to pay the royalties was 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 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 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, work including cinematograph films, or films and films or tapes used for radio or television broadcasting, or any patent, trade ▇▇▇▇, design or modelsmodel, plan, or secret formula or process, 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 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, a local 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 liability to pay the royalties was incurred, 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 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 the royalties mentioned in sub-paragraph a) of paragraph 3 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. 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, or films or tapes used for radio or television broadcasting, ,: a) any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, computer software, or industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience; b) any copyright of literary, artistic or scientific work including cinematograph films and films or tapes for television or radio broadcasting. (4. ) The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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, a local 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 liability to pay the royalties was 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 beneficially owned by a resident of the other Contracting State may shall be taxed taxable only 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 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, work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, or secret formula or process, or for information concerning industrial, commercial or scientific experience. 43. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties 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. 54. Royalties shall be deemed to arise in a Contracting State when the payer is that State, a local 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 liability to pay the royalties was incurred, 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. 65. 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 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, work including cinematograph films, or films and films or tapes used for television or radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, 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 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 StateState itself, a local 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 liability to pay the royalties was 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 beneficially owned by a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties arising in a Contracting State may also be taxed in the Contracting that 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, work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇trademark, design or modelsmodel, 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. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 where the payer is that State, a local 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 liability to pay the royalties was incurred, incurred 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 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 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 or tapes used and recordings for radio or and television broadcasting, any patent, know how, computer programmes, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or for information concerning industrial, commercial or scientific experienceexperience or for the use of, or the right to use, industrial, commercial or scientific equipment. 43. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties 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 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 such permanent establishment or fixed base. In such case the provisions of Article Articles 7 or Article 1415, as the case may be, shall apply. 54. Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that Contracting State, a political subdivision of that State, a local 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 liability to pay the royalties was 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. 65. 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 case, the excess part of the payments shall remain taxable 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. Notwithstanding the provisions of paragraph 2, (a) copyright royalties and other like payments in respect of the production or reproduction of any literary, dramatic, musical or other artistic work (but 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); (b) royalties for the use of, or the right to use, computer software; and (c) where the payer and the beneficial owner of the royalties are not related persons, royalties for the use of, or the right to use, any patent or any information concerning industrial, commercial or scientific experience (but not including any such information provided under a rental or franchise agreement), arising in a Contracting State and paid to a resident of the other Contracting State who is the beneficial owner thereof 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, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or processprocess or other 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. 45. The provisions of paragraphs 1 2 and 2 3 shall not apply if the beneficial owner of the royalties 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. 56. Royalties shall be deemed to arise in a Contracting State when the payer is that StateState itself or its state authorities, a including local authority authorities thereof or 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 liability obligation to pay the royalties was 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. 67. 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. 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, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, 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 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, a local 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 liability to pay the royalties was 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 be taxed in that other State. (2. ) However, such the royalties mentioned in sub-paragraph a) of paragraph 3 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. 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, or films or tapes used for radio or television broadcasting, ,: a) any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, computer software, or industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience; b) any copyright of literary, artistic or scientific work including cinematograph films and films or tapes for television or radio broadcasting. (4. ) The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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, a local 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 liability to pay the royalties was 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 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, work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, 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 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 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, a local 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 liability to pay the royalties was 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 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 for: (a) he use of, or the right to use, any copyright of literary, artistic or scientific work, including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or any copyright scientific work, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience; (b) he use of, or the right to use, cinematograph films, or tapes for radio or television broadcasting, any copyright of literary or artistic work. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 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 StateState itself, a political subdivision, a local authority thereof or a statutory body thereof, or a resident of that State. Where, however, the person paying the such 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 liability obligation to pay the royalties was 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 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 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 5 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 films, tapes or films or tapes used discs for radio or and television broadcasting), any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, process 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 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, 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, a local 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 liability to pay right, property in respect of which the royalties was incurredare paid is effectively connected, 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 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 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, then the tax so charged shall not exceed 10 per cent 5% (five percent) of the gross amount of the such 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, use any copyright of literary, artistic artistic, or scientific work, work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or processprocess or for the use of, or the right to use, industrial, commercial, or scientific equipment or for information concerning industrial, commercial or scientific experienceexperience but the term royalties does not include payment in respect of the operation of mines or quarries or exploitation of natural resources or related activities. 4. The provisions provisioris of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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, located 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 directly connected with such permanent perrnanent establishment or fixed base. In 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 StateState itself, a political subpision, a local authority thereof or a resident of that ihat 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 liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment or 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. 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 lastiast-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 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, work including software and cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, drawing, design or modelsmodel, 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, industrial commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 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, a local 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 liability to pay the royalties was 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 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 it arises 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. 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, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, 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 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, a local 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 liability to pay the royalties was incurred, 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 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 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 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: (a) the use of, or the right to use, any copyright of literarycopyright, artistic or scientific work, including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇trademark, design or modelsmodel, plan, secret formula or process, or other like property or right; (b) the use of, or the right to use: (i) motion picture films; (ii) 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; (c) the use of, or the right to use, any industrial, scientific or commercial equipment; (d) knowledge or information concerning industrial, technical, commercial or scientific experience; (e) total or partial forbearance in respect of the use or supply of any property or right referred to in this paragraph. 4. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the royalties 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, a local authority thereof 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 liability to pay the royalties was incurred, and such royalties are borne by deductible in determining the profits attributable to 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 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, work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, 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. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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, a local 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 liability to pay the royalties was 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 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, work including software and cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, drawing, design or modelsmodel, 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, industrial commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 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, a local 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 liability to pay the royalties was 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 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, work (including cinematograph films, or and films or tapes used for radio or television broadcasting), any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, or for information (know-how) concerning industrial, commercial or scientific experience. (4. ) The provisions of paragraphs 1 (1) and 2 (2) shall not apply if the beneficial owner of the royalties 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 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, a local 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 liability to pay the royalties was 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 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 Agreement. (6) No relief shall be available under this Article 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. (7) Royalties shall be deemed to arise in a Contracting State when the payer is 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 in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated.

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 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 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: (a) the use of, or the right to use, any copyright of literarycopyright, artistic or scientific work, including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇trademark, design or modelsmodel, plan, secret formula or process, or other like property or right; (b) the use of, or the right to use: (i) motion picture films; (ii) 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; (c) the use of, or the right to use, any industrial, scientific or commercial equipment; (d) knowledge or information concerning industrial, technical, commercial or scientific experience; (e) total or partial forbearance in respect of the use or supply of any prop‐ erty or right referred to in this paragraph. 4. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial bene‐ ficial owner of the royalties 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, a local authority thereof or a resident of that Contracting State. Where, however, the person paying the royalties▇▇▇‐ alties, 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 liability to pay the royalties was incurred, and such royalties are borne by deductible in determining the profits attributable to such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent ▇▇▇▇▇▇‐ ent 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▇▇▇‐ alties, 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 Art‐ icle 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 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, tapes or films or tapes used discs for radio or television broadcasting), any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, 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 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, 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. Royalties shall be deemed to arise in a Contracting State when the payer is that State, a local authority thereof or a resident of that 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 liability to pay right or property in respect of which the royalties was incurredare paid is effectively connected, 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. 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 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, 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, work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, 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. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 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, a local 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 liability obligation to pay the royalties was 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 and 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, work (including cinematograph films and films, tapes or films or tapes used discs for radio or television broadcasting), any patent, trade ▇▇▇▇mark, design or modelsmodel, 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. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 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, a local authority thereof or a resident of that 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 liability to pay right or property in respect of which the royalties was incurredare paid is effectively connected, 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-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. No relief shall be available under the Article if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the shares or rights in respect of which the royalties is 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 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, work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment or for information (know-how) concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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 baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, (Business Profits) shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State, a local 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 liability to pay the royalties was 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 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 a 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. 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, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, 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 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, a local 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 liability to pay the royalties was 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 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 exceed: (a) 5 per cent of the gross amount of the royaltiesroyalties in respect of the use of or the right to use industrial, commercial or scientific equipment; and (b) 7.5 per cent of the gross amount of the royalties 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 copyright of literary, artistic or scientific work, work (including cinematograph films, cinematographic films and recordings on tape or films or tapes other media used for radio or television broadcastingbroadcasting or other means of reproduction or transmission), any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or 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 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 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, a local 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 liability to pay the royalties was 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 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, work (including cinematograph films, or and films or tapes used for radio or television broadcasting), any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or for information (know-how) concerning industrial, commercial or scientific experience. (4. ) The provisions of paragraphs 1 (1) and 2 (2) of this Article shall not apply if the beneficial owner of the royalties 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 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 where the payer is that State, a local 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 liability obligation to pay the royalties was incurred, incurred and such the royalties are borne by such that 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 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 Agreement. (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 obtain a tax advantage under 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 Contracting State, if such resident is a beneficial owner of the royalties. 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, 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, software, including cinematograph films, films or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, 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. 4. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the royalties 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 beof this Agreement, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State, a local 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 liability to pay the royalties was incurred, 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, 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, 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 workwork including software, including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, and payments 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 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 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, a local 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 liability to pay the royalties was incurred, 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. 7. The provisions of this Article shall not apply if 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 Contracting State. 2. However, such royalties may also be taxed in the Contracting State in m 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 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 workwork including software, including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, 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. 4. The provisions of paragraphs paragraph 1 and 2 of this Article shall not apply if the beneficial owner of the royalties 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, 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 Convention shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State, a local 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 liability to pay the royalties was 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 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, work (including cinematograph films, or and films or tapes used for radio or television broadcasting), any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, or for information (know-how) concerning industrial, commercial or scientific experience. (4. ) The provisions of paragraphs 1 (1) and 2 (2) of this Article shall not apply if the beneficial owner of the royalties 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 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 where the payer is that State, a local 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 liability obligation to pay the royalties was incurred, incurred and such the royalties are borne by such that 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 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 Agreement. (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 obtain a tax advantage under 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 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, work including cinematograph films, or films and films or tapes used and other means of image or sound reproduction for radio or television broadcastingbroad-casting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, 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 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, a local 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 liability to pay the royalties was 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 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 workwork including software, including cinematograph films, or films and films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, or secret formula or process, 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 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, a local 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 liability to pay the royalties was incurred, 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 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 the royalties referred to in paragraph 1 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, work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, or for the use of, or the right to use, any 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 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 baseestablishment. 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, a local 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 liability to pay the royalties was 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 beneficially owned by a resident of the other Contracting State may shall be taxed taxable only in that other State. 2. However, such royalties the payments of the kind referred to in sub-paragraph b) of paragraph 3 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 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, : a) any copyright of literary, artistic or scientific work, work (except for computer software) including cinematograph films, or and films or tapes used for television or radio or television broadcasting, ; b) any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, tailor made computer software, or 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 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, a local 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 liability to pay the royalties was 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 contracting state and paid to a resident of the other Contracting State contracting state may be taxed in that other Statestate. (2. ) However, such royalties may also be taxed in the Contracting State 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 State, the tax so charged shall not exceed 10 per cent 8% 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, work (including cinematograph films, or and films or tapes used for radio or television broadcasting), any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, or for information (know-how) concerning industrial, commercial or scientific experience. (4. ) (deleted) (5) The provisions of paragraphs 1 (1) and 2 (2) of this article shall not apply if the beneficial owner of the royalties or of the sums derived, being a resident of a Contracting Statecontracting state, carries on business in the other Contracting State contracting state in which the royalties or the sums arise, through a permanent establishment situated therein, or performs in that other State state independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid or the sums are derived is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 1414 of this agreement, as the case may be, shall apply. 5. (6) Royalties shall be deemed to arise in a Contracting State contracting state when the payer is that State, a local authority thereof or a resident of that Statestate. Where, however, the person paying the royalties, whether he is a resident of a Contracting State contracting state or not, has in a Contracting State contracting state a permanent establishment or a fixed base in connection with which the liability obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State contracting 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 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 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 Statecontracting state, due regard being had to the other provisions of this Agreementagreement. (8) 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. (9) In the event that a resident of a contracting state is denied relief from taxation in the other contracting state by reason of the provisions of paragraph (8) of this article, the competent authority of the other contracting state shall notify the competent authority of the first-mentioned contracting state.

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 arising in a Contracting State may also be taxed in the Contracting that 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, or films and films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, 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 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, a local authority thereof or a resident of that 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 liability to pay the royalties was incurred, 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 Stale and paid to a resident of the other Contracting Slate may be taxed in the First mentioned State. The lax so charged shall not exceed (5) five percent of the gross amount of the royalties. 2. Notwithstanding the provisions of paragraph I. the copyright royalties paid in respect of the author’s right and other similar remuneration for the reproduction of literary, dramatic, musical or artistic work, arising in a Contracting State and paid to a resident of the other Contracting State may who is liable to lax on them, once the recipient of said royalties is the beneficial owner, shall be taxed in that other State. 2. However, such royalties may also be taxed exempt from tax in the Contracting State in which they arise and according to the laws of that first- mentioned 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 pay minis of any kind received am kincirectiveci as a consideration for the use of, . or the right to use, . any copyright of literary, ofliterary. artistic or scientific work, work (including cinematograph films and films, tapes or films or tapes used discs for radio or television broadcasting, broadcasting ). any patent, . trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, of 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 royalties, being a resident of a Contracting State, carries on business business- in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, therein or performs perform in that other State Stale independent personal services service's from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively effective!) connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 1414 shall apply, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State, a local authority thereof or a resident of that StateSlate. 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 liability to pay right, property in respect of which the royalties was incurredare paid is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to lo 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, 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 workwork including software, including cinematograph films, or films and films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, or secret formula or process, 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 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, a local 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 liability to pay the royalties was incurred, 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 AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned 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 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, work including cinematograph cinematographic films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, 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 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 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 StateState itself, a political subdivision, a local 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 liability to pay the royalties was 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.Convention.‌

Royalties. (1. ) Royalties arising in a Contracting State and paid to beneficially owned 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 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, work including cinematograph films, or films and films or tapes used and other means of image or sound reproduction for radio or television broadcastingbroad-casting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. The term “royalties” shall also include payments of any kind: a) for the use or the right to use a person’s name, picture or any other similar personality rights and on payments received as consideration for the public playing of the records of entertainers' or sportsmen's performances and b) for the use of, or the right to use, industrial, commercial or scientific equipment; the provision of subparagraph b) shall cease to be applied in respect of amounts paid after the 31 December 2014. (4. ) The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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, 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, a local 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 liability to pay the royalties was incurred, 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 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, work including cinematograph films, films or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, 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. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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, a local 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 liability to pay the royalties was 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 beneficially owned by a resident of the other Contracting State may shall be taxed taxable only 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 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, work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, or secret formula or process, or for information concerning industrial, commercial or scientific experience. 43. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties 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. 54. Royalties shall be deemed to arise in a Contracting State when the payer is that State, a local 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 liability to pay the royalties was incurred, 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. 65. 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 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 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, work including cinematograph cinematography films and works on films, tapes or films other means of reproduction for use in connection with television or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or modelsmodel, plan, secret formula or process, or for information (know-how) 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 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, 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, a local 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 liability to pay the royalties was incurred, 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 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 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, according to its laws. (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 to use, any copyright of literary, artistic or scientific work, work including cinematograph films, or films and films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or modelsmodel, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. (4. ) The provisions of paragraphs 1 (1) and 2 (2) shall not apply if the beneficial owner of the royalties 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 to 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 StateState itself, a political subdivision, a local 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 liability to pay the royalties was 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 beneficially owned 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 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 8 % 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 cinematographic films, or films films, tapes and other means of image or tapes used for radio or television broadcastingsound reproduction, any patent, trade ▇▇▇▇, design or modelsmodel, 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. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties 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, 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, a local authority thereof or a resident of that Contacting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting Contacting State a permanent establishment or a fixed base in connection with which the liability to pay the royalties was incurred, 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 AgreementConvention.