Common use of Royalties Clause in Contracts

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 Party, carries on business in the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 base, then such royalties shall be deemed to arise in the 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 Party, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films films, or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 and films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 per cent 12.5% of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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, 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 Party State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 base, then such royalties shall be deemed to arise in the Party 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 PartyState, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 and films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 5 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or films or tapes used discs for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that the other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 and films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇mark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 5 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or films or tapes used discs for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇mark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that the other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 7 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 computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. (1. ) Royalties arising in a Contracting Party State and paid to beneficially owned by a resident of the other Contracting Party State may be taxed in that other PartyContracting State. (2. ) However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyContracting State, but if the recipient and the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 computer software, patent, trade ▇▇▇▇mark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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, 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 Party State when the payer is a resident of that PartyContracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise arise, and according to the laws of that PartyContracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Partyroyalties, the tax so charged shall not exceed 8 exceed: (a) 10 per cent of the gross amount of the royaltiesroyalties where the royalties are as defined in sub-paragraph (a) of paragraph 3; (b) 15 per cent of the gross amount of the royalties where the royalties are as defined in sub-paragraph (b) of paragraph 3. 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 computer software, patent, trade ▇▇▇▇, design or model, 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, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is that State or a statutory body thereof, or a resident of that Party. WhereContracting State; where, however, the person paying the such royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 of each Contracting PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 10 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, software, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party State in which the permanent establishment or a fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or and films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. (1. ) Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. (2. ) However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 5 per cent of the gross amount of the royalties. (3. ) The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or films or tapes used discs for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇mark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that the other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 5 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or films or tapes used discs for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial commercial or scientific equipment or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting Party, carries on business in the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that the other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 base, then such royalties shall be deemed to arise in the 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 Party, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the recipient and the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 software, cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information (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, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party 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 a fixed base. In such case, case the provisions of Article 7 or and Article 14, as the case may be, 15 shall apply. 5. Royalties shall be deemed to arise in a Contracting Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 a fixed base, base then such royalties shall be deemed to arise in the Party State in which the permanent establishment or a fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other 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 PartyState, due regard being had to the other provisions of this Agreement. 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 Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. (2. ) However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 5 per cent of the gross amount of the royalties. (3. ) The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or films or tapes used discs for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that the other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party territory and paid to a resident of the other Contracting Party territory may be taxed in that other Partyterritory. 2. However, such royalties may also be taxed in the Contracting Party territory in which they arise and according to the laws of that Partyterritory, but if the beneficial owner of the royalties is a resident of the other Contracting Partyterritory, the tax so charged shall not exceed 8 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 computer software, patent, trade ▇▇▇▇mark, design or model, 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 Partyterritory, carries on business in the other Contracting Party territory in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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, 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 Party territory when the payer is a resident of that Partyterritory. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party territory or not, has in a Contracting Party 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 have arisen in the Party 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 each Contracting Partyterritory, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 5 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 including cinematograph films, or films films, tapes and other means of image or tapes used for radio or television broadcastingsound reproduction, any computer software, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting Party, carries on business in the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 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 Party, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 5 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 (including cinematograph films, films, tapes or films or tapes discs used for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting Party, carries on business in the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that the other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 base, then such royalties shall be deemed to arise in the Party in which the permanent establishment or a fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other 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 Party, 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 Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 Party, carries on business in the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base or 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 base, then such royalties shall be deemed to arise in the 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 Party, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 and films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇mark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 5 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including software as well as cinematograph films, or and films or tapes used for television or radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 8 or Article 1415, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise arise, and according to the laws of that PartyState, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Partyroyalties, the tax so charged shall not exceed 8 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 and films or tapes used for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information (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, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the recipient and the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 software, cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information (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, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party 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 a fixed base. In such case, case the provisions of Article 7 or and Article 14, as the case may be, 15 shall apply. 5. Royalties shall be deemed to arise in a Contracting Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 a fixed base, base then such royalties shall be deemed to arise in the Party State in which the permanent establishment or a fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other 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 PartyState, due regard being had to the other provisions of this Agreement. 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 Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such the royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 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, cinematographic films and films and tapes for television or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇trademark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 (Business Profits) or Article 1414 (Independent Personal Services), as the case may be, be shall apply. 5. Royalties shall be deemed to arise in a Contracting Party State when the payer is that State itself, a political subdivision, a local authority or a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 establishment, or fixed base, base then such royalties shall be deemed to arise in the Party 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 recipient 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 artistic, scientific or scientific other work including cinematograph cinematography films, or and films or tapes used and recordings for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyContracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 3 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 computer software, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting Party, carries on business in the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 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 Party, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to whose beneficial owner is a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting Partycontracting State, the tax so charged shall not exceed 8 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 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 computer software, patent, trade ▇▇▇▇mark, design designs or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, or scientific equipment or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party 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 Party when State where the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 and films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇mark, design or model, 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 Party, carries on business in the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 base, then such royalties shall be deemed to arise in the 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 Party, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 5 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 including cinematograph films, or films films, tapes and other means of image or tapes used for radio or television broadcastingsound reproduction, any computer software, patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting Party, carries on business in the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 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 Party, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 television or radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 per cent 10% of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 5 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or films or tapes used discs for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial commercial or scientific equipment or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting Party, carries on business in the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that the other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 base, then such royalties shall be deemed to arise in the 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 Party, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 10 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and films or tapes used for radio or television broadcastingbroad-casting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1. ) Royalties arising in a Contracting Party State and paid to beneficially owned by a resident of the other Contracting Party State may be taxed in that other PartyContracting State. (2. ) However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyContracting State, but if the recipient and the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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, 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 Party State when the payer is a resident of that PartyContracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise arise, and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 per cent exceed: (a) 10 percent of the gross amount of such payments if they are made as consideration for the royalties.use of, or the right to use any copyright of literary, artistic or scientific work; 3. The term "royalties" (b) 15 percent of the gross amount of such payments if they are made 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 computer software, patent, trade ▇▇▇▇trademark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, or for the use of, or the right to use, industrial, commercial or scientific equipment, cinematograph films or tapes for television or broadcasting. 3. The provisions of paragraph 2 shall likewise apply to the gains from the alienation of any right or property giving rise to such royalties if such right or property is alienated by a resident of a Contracting State for exclusive use in the other Contracting State and the payment of such right or property is borne by an enterprise of that other State or a permanent establishment or fixed base situated therein. 4. A royalty shall be deemed to arise in a Contracting State if the payer is that State itself, a political subdivision or local authority thereof or a resident of that State. Where, however, the person paying the royalty whether he is a resident of a Contracting State or not, has in a Contracting State permanent establishment or a fixed base in connection with which the obligation to pay the royalties was incurred and such royalties are borne by that 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. 5. The provisions of paragraphs 1 1,2 and 2 3 shall not apply if the beneficial owner recipient of the royalties, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 base, then such royalties shall be deemed to arise in the 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 recipient or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner recipient in the absence of such relationship, relationship the provisions of this Article shall apply only to the last-mentioned amounta mount. In such that case, the excess part of the payments shall remain taxable according to the laws law of each case Contracting PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 per cent of the gross amount of the royalties. 3. The term "“royalties" ”, as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 Party, carries on business in the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 base, then such royalties shall be deemed to arise in the 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-last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting Party, due regard being had to the other provisions of this Agreement. Note 14: There have been no changes to this Article as the MLI has no impact on it.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph cinematography films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 1415, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting Party State when the payer is a resident of that PartyContracting State. Where, however, the person paying the royalties, whether he that person is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 5 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or films or tapes used discs for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇mark, design or model, 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 Party, carries on business in the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that the other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 base, then such royalties shall be deemed to arise in the Party in which the permanent establishment or fixed base is situated.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 Party, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise arise, and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 10 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or films or tapes discs used for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he that person is a resident of a Contracting Party State or not, has in a Contracting Party 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 base, then such royalties shall be deemed to arise in the Party 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party and paid to beneficially owned by a resident of the other Contracting Party may shall be taxed taxable only in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 per cent of the gross amount of the royalties. 3. The term "royalties" ―royalties‖ as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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, being a resident of a Contracting Party, carries on business in the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 base, then such royalties shall be deemed to arise in the Party 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 Party, due regard being had to the other provisions of this Agreement. 5. Royalties shall be deemed to arise in a Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Party or not, has in a Party a permanent establishment in connection with which the liabilities 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 Party in which the permanent establishment is situated.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may shall be taxed taxable only in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇mark, design or model, 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, being a resident of a Contracting Party, carries on business in the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 base, then such royalties shall be deemed to arise in the Party 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 Party, due regard being had to the other provisions of this Agreement. 5. Royalties shall be deemed to arise in a Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Party or not, has in a Party a permanent establishment in connection with which the liabilities 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 Party in which the permanent establishment is situated.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 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 (including cinematograph films, 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 computer software, patent, trade ▇▇▇▇, design or model, 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 Party, carries on business in the other Contracting Party in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party 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 Party when where the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 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 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 Party, due regard being had to the other provisions of this Agreement.mentioned

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 10 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or films or tapes used discs for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇mark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that the other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 per cent ten percent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received 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 computer software, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is that State itself, a political subdivision, a local authority or a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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, person the amount of the royalties, having regard to the use, right or information for which they the are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments payment shall remain taxable according to the laws of each Contracting PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may shall be taxed taxable only in that other Party. 2. However, Party if such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if resident is the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 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 including software as well as cinematograph films, or films and films or tapes used for television or radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 43. The provisions of paragraphs 1 and 2 paragraph1 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting Party, carries on business in the other Contracting Party in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party 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. 54. Royalties shall be deemed to arise in a Contracting Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 base, then such royalties shall be deemed to arise in the Party 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 Party, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 computer software, patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1. ) Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. (2. ) However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 computer software, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experienceexperi­ ence. The term “royalties“ shall also include payments of any kind 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 registration of entertainers' or sportsmen's performances by radio or television. (4. ) The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royaltiesroyal­ ties, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 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 (including cinematograph films, 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 computer software, patent, trade ▇▇▇▇, design or model, 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 Party, carries on business in the other Contracting Party in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party 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 Party when where the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 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 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 Party, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇mark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 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 a copyright of a literary, artistic or scientific work work, including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, trademark design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is that State itself, a political subdivision, a local authority or a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party State a permanent establishment or a fixed base in connection with which the liability to pay the royalties royal ties was incurred, incurred and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Party 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, 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party State and paid to beneficially owned by a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting Partycontracting State, the tax so charged shall not exceed 8 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 software, cinematograph films, or films or tapes used for radio and other means of image or television broadcastingsound reproduction, any computer software, patent, trade ▇▇▇▇mark, design drawings, designs or modelmodels, planplans, secret formula formulas or processprocesses, or for information concerning 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, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this AgreementConvention. 7. The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the royalties are paid to take advantage of this Article by means of that creation or assignment.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise arise, and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 10 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or films or tapes discs used for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he that person is a resident of a Contracting Party State or not, has in a Contracting Party 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 base, then such royalties shall be deemed to arise in the Party 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 exceed: (a) 5 per cent of the gross amount of royalties paid for the use of, or the right to use, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience; (b) 10 per cent of the gross amount of the royaltiesroyalties in all other cases. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇mark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 5 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 including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting Party, carries on business in the other Contracting Party in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 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 Party, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 and films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇mark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. (1. ) Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. (2. ) However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 5 per cent of the gross amount of the royalties. (3. ) The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or films or tapes used discs for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇mark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that the other Party State independent personal services from a fixed base situated therein, and the right or property properQ 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party State a permanent establishment or a fixed base in connection with which the liability liabiliQ to pay Agreement Between the Government of the State of Qatar and the Government of the Republic of Austria For the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital 10 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 a computer software, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1. ) Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. (2. ) However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is that State itself, a political subdivision, a local authority or a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party State and paid to beneficially owned by a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise arise, and according to the laws of that PartyState, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Partyroyalties, the tax so charged shall not exceed 8 10 per cent of the gross amount of the royalties. 3. The term "«royalties" » as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or films or tapes used discs for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 base, then such royalties shall be deemed to arise in the Party 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 a case, the excess part of the payments shall remain taxable according to the laws of each Contracting PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident residen t of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Partyroyalties, the tax so charged shall not exceed 8 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 works including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇mark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is that State itself, a political sub -division, a local authority or a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 ow ner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned last -mentioned amount. In such case, the excess part of the payments payment shall remain taxable according to the laws of each Contracting PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 5 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or films or tapes used discs for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, 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, being a resident of a Contracting Party, carries on business in the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that the other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 base, then such royalties shall be deemed to arise in the 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 Party, due regard being had to the other provisions of this Agreement. Note 14: There have been no changes to this Article as the MLI has no impact on it.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Partyroyalties, the tax so charged shall not exceed 8 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 works including cinematograph cinematography films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is that State itself, a political sub-division, a local authority or a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 payment shall remain taxable according to the laws of each Contracting PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 5 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or films or tapes used discs for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇mark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that the other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. (1. ) Royalties arising in derived from a Contracting Party and paid to State by a resident of the other Contracting Party may State shall be taxed taxable only in that other PartyState. (2. ) However, such royalties may also be taxed in the Contracting Party in State from which they arise are derived, and according to the laws law of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 10 per cent of the gross amount of the such royalties. (3. ) The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio television or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 experience. (4. ) The provisions of paragraphs 1 and 2 paragraph (1) shall not apply if the beneficial owner recipient of the royalties, being a resident of a Contracting PartyState, carries on business has in the other Contracting Party State in which the royalties arise, through arise a permanent establishment situated therein, or performs in that other Party 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 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 be derived from a Contracting Party State when the payer is that State itself, a political subdivision or a local authority thereof or a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 be derived from the Party Contracting State in which the permanent establishment or fixed base is situated. (6. ) Where, by reason of owing to a special relationship between the payer and the beneficial owner recipient or between both of them and some other person, the amount of the royaltiesroyalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-last- mentioned amount. In such that case, the excess part of the payments shall remain taxable according to the laws law of each Contracting Party, State due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyContracting State. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise arise, and according to the laws of that PartyState, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Partyroyalties, the tax so charged shall not exceed 8 6 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 cinematographic films or tapes used and recordings for radio or television broadcastingand television, any computer software, patent, trade ▇▇▇▇mark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party Contracting State independent personal services from a fixed base situated thereinbase, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case, 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 Party State when the payer is that State itself, a political subdivision, a local authority or a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 base, then such royalties shall be deemed to arise in the Party Contracting State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royaltiesroyalties paid, having regard to the use, right to use or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such a relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting PartyState, with due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident reside- nt of the other Contracting Party may be taxed in that other Contracting Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise arise, and according to the laws of that Party, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Partyro- yalties, the tax so charged shall not exceed 8 per cent 15 percent of the gross amount of the royalties. 3. The term "royalties" as ”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 scientif- ic work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, or scien- tific equipment, or for information concerning industrial, commercial co- mmercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial b- eneficial owner of the royalties, being a resident of a Contracting Contr- acting Party, carries on business in the other Contracting Party Pa- rty in which the royalties arise, through a permanent establishment establi- shment situated therein, or performs in that other Party independent inde- pendent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are a- re paid is effectively connected with such permanent establishment establis- hment 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 Party when the payer is that Party itself, a political subdivision, a lo- cal authority or a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Co- ntracting Party or not, has in a Contracting Party a permanent establishment or a fixed base in connection with which the liability li- ability 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 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 oth- er 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 pro- visions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain r- emain taxable according to the laws of each Contracting Party, due regard being had to the other provisions of this AgreementAgreement .

Royalties. 1. Royalties arising in a Contracting Party State and paid to beneficially owned by a resident of the other Contracting Party may State shall be taxed taxable only in that other PartyContracting State. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyContracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 10 per cent of the gross amount of the royalties. 3. The term "«royalties" » as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyContracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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-last mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party may State shall be taxed taxable only in that other Party. 2. However, State if such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if a resident is the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 per cent of the gross amount of the royalties. 32. The term "royalties" as used in this Article means payments of any kind received paid as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, and other recordings of sounds or films or tapes used for radio or television broadcastingimages, software, any computer software, patent, trade ▇▇▇▇, design or model, 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, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Articles 7 or Article 14, as the case may be, shall apply. 54. Royalties shall be deemed to arise in a Contracting Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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, case the excess part of the payments shall remain taxable according to the laws of each the Contracting Party, State due regard being had to the other provisions of this AgreementConvention.

Royalties. (1. ) Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. (2. ) However, such royalties may also be taxed in the Contracting Party State in which they arise and according to in accordance with the laws law of that Party, Contracting State; but if the beneficial owner of the where such royalties is are paid to a resident of the other Contracting Party, State who is subject to tax there in respect thereof the tax so charged in the Contracting State in which the royalties arise shall not exceed 8 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 and films or tapes used for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4. ) The provisions of paragraphs 1 and 2 paragraph (2) of this Article shall not apply if the beneficial owner recipient of the royalties, being a resident of a Contracting PartyState, carries on business has in the other Contracting Party in which the royalties arise, through State a permanent establishment situated therein, or performs in that other Party independent personal services from a fixed base situated therein, and the right or property in respect of which giving rise to the royalties are paid is effectively connected with such a business carried on through that permanent establishment or fixed baseestablishment. In such a case, the provisions of Article 7 or Article 14, as the case may be, 8 shall apply. (5. Royalties shall be deemed to arise in ) Any provision of the law of a Contracting Party when State which requires royalties paid by a company to be left out of account as a deduction in computing the payer company's taxable profits as being a dividend or distribution shall not operate in relation to royalties paid to a resident of the other Contracting State. The preceding sentence shall not however apply to royalties derived by a company which is a resident of that Party. Where, however, other Contracting State where-- (a) the person same persons participate directly or indirectly in the management or control of the company paying the royalties and the company deriving the royalties, whether he is a resident ; and (b) more than 50 per cent of a Contracting Party or not, has the voting power in a Contracting Party a permanent establishment or a fixed base in connection with which the liability to pay company deriving the royalties was incurred, and such royalties are borne is controlled directly or indirectly by such permanent establishment a person or fixed base, then such royalties shall be deemed to arise persons resident in the Party Contracting State in which the permanent establishment or fixed base company paying the royalties is situatedresident. (6. ) Where, by reason of owing to a special relationship between the payer and the beneficial owner recipient or between both of them and some other person, the amount of the royaltiesroyalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such that case, the excess part of the payments shall remain taxable according to the laws law of each Contracting PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 3 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 or other means of image or sound reproduction for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 Party, carries on business in the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 base, then such royalties shall be deemed to arise in the 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 Party, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise arise, and according to the laws of that PartyContracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Partyroyalties, the tax so charged shall not exceed 8 exceed: (a) 10 per cent of the gross amount of the royaltiesroyalties where the royalties are as defined in sub-paragraph (a) of paragraph 3; (b) 15 per cent of the gross amount of the royalties where the royalties are as defined in sub-paragraph (b) of paragraph 3. 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 computer software, patent, trade ▇▇▇▇, design or model, 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, being a resident res ident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is that State or a statutory body thereof, or a resident of that Party. WhereContracting State; where, however, the person paying the such royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 of each Contracting PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 computer software, patent, trade ▇▇▇▇mark, design or model, 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 paragraph 1 and paragraph 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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, then such royalties shall be deemed to arise in the Party 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may shall be taxed taxable only in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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, being a resident of a Contracting Party, carries on business in the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 base, then such royalties shall be deemed to arise in the Party 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 Party, due regard being had to the other provisions of this Agreement. 5. Royalties shall be deemed to arise in a Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Party or not, has in a Party a permanent establishment in connection with which the liabilities 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 Party in which the permanent establishment is situated.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 5 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or films or tapes used discs for radio or television broadcasting), any computer software, patent, trade ▇▇▇▇, design or model, 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 Party, carries on business in the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that the other Party 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 Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 base, then such royalties shall be deemed to arise in the 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 Party, due regard being had to the other provisions of this Agreement.

Royalties. (1. ) Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. (2. ) However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 television broadcastingand television, any computer software, patent, trade ▇▇▇▇, design or model, 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. The term “royalties” shall also include payments of any kind for the use or the right to use a person's name, picture or any other similar personality rights. (4. ) The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, therein or performs in that other Party State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5. ) Royalties shall be deemed to arise in a Contracting Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party State a permanent establishment or a fixed base 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise arise, and according to the laws law of that PartyState, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Partyroyalties, the tax so charged shall not exceed 8 15 per cent of the gross amount of the royalties. 3. Notwithstanding the provisions of paragraph 2, approved industrial royalties derived from Malaysia by a resident of Italy who is the beneficial owner thereof shall be exempt from Malaysian tax. 4. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer softwarework, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. The term, however, does not include any royalty or other amount paid in respect of motion picture films or of tapes for radio or television broadcasting. 45. The provisions of paragraphs 1 1, 2 and 2 3 of this Article shall not apply if the beneficial owner recipient of the royalties, being a resident of a Contracting PartyState, carries on business has in the other Contracting Party State in which the royalties arise, through arise a permanent establishment situated therein, or performs in that other Party 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 is effectively connected. In such a case, 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 applytaxable in that other State according to its own law. 56. Royalties shall be deemed to arise in a Contracting Party State when the payer is that State itself, a resident of that Party. Wherepolitical or an administrative subdivision, however, the person paying the royalties, whether he is a local authority or statutory body thereof or a resident of a Contracting Party State or not, has in a Contracting Party 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 Party State in which the permanent establishment or fixed base is situated. 67. Where, by reason of owing to a special relationship between the payer and the beneficial owner recipient or between both of them and some other person, the amount of the royaltiesroyalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such that case, the excess part of the payments shall remain taxable according to the laws law of each Contracting PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in the country of a Contracting Party and paid to a resident of the country of the other Contracting Party may be taxed in that other Partycountry. 2. However, such royalties may also be taxed in the country of the Contracting Party in which they arise and according to the laws of that Partycountry, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Partyroyalties, the tax so charged shall not exceed 8 per cent 10% of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, films or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of the country of a Contracting Party, carries on business in the country of the other Contracting Party in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party country 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 the country of a Contracting Party when the payer is the authority of the country of that Contracting Party itself, a local authority or a resident of that Partycountry. Where, however, the person paying the royalties, whether he is a resident of the country of a Contracting Party or not, has in the country of a Contracting 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 base, then such royalties shall be deemed to arise in the Party country 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 country of the Contracting Party, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 7 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 computer software, patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or for the use of or the right to use 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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, use or 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇mark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 per cent of the gross amount of the royalties.exceed 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph cinematographic films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or other intangible property, 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 sha l not apply if the beneficial owner of the royalties, being a resident of a Contracting PartyState, carries car ies on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyContacting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 base, then such royalties shall be deemed to arise in the Party Contracting State in which the permanent establishment or the 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 sha l 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1. ) Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. (2. ) However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 per cent 10 percent of the gross amount of the royalties. (3. ) The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. The term “royalties” shall also include payments of any kind 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 registration of entertainers’ or sportsmen’s performances by radio or television. (4. ) The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. (1. ) Royalties arising in a Contracting Party State which are derived and paid to beneficially owned by a resident of the other Contracting Party State may be taxed in that other PartyState. (2. ) However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws law of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 15 per cent of the gross amount of the royalties. (3. ) The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcastingwork, any computer software, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (4. ) The provisions of paragraphs 1 (1) and 2 (2) of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party independent personal State professional services from a fixed base situated therein, and the right rights or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such a case, the provisions of Article 7 or Article 14, as the case may bemaybe, shall apply. (5. ) Royalties shall be deemed to arise in a Contracting Party when State where the payer is that State itself, a political subdivision, a local authority or a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 the royalties shall be deemed to arise in the Party Contracting State in which the permanent establishment or fixed base is situated. (6. ) Where, by reason of owing to 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 royalties paid exceeds for which they are paid, exceeds whatever reason 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 PartyState, due regard being had to the other provisions of this AgreementConvention. (7) The provisions of this Article shall not apply to dividends on founders shares issued in Egypt as consideration for rights mentioned in paragraph (3) of this Article and which are taxed in Egypt in accordance with the provisions of Article 1 of Law No. 14 of 1939, as it may be amended from time to time in minor respects without affecting the general principle thereof. In such a case, the provisions of Article 10 of this Convention shall apply.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 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 of use, any copyright of literary, artistic or scientific work including cinematograph films, or and films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party State independent personal services from a fixed base situated therein, and the right or of property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 14, 14 as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting Party State when the payer is that State itself, a political subdivision, a local authority or a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party contracting State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 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 (including cinematograph films, 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 computer software, patent, trade ▇▇▇▇mark, design or model, 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 Party, carries on business in the other Contracting Party in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party 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 Party when where the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting 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 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 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 Party, due regard being had to the other provisions of this Agreement.

Royalties. (1. ) Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. (2. ) However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 per cent 10 percent of the gross amount of the royalties. (3. ) The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. The term “royalties” shall also include payments of any kind 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 registration of entertainers' or sportsmen's performances by radio or television. (4. ) The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 10 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph cinematography films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇mark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 1415, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting Party State when the payer is a resident of that PartyContracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party Con- tracting State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties ▇▇▇- alties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 re- ceived as a consideration for the use of, or the right to use, any copyright of literary, artistic ar- tistic or scientific work including software, cinematograph films, or films or tapes used for radio and other means of image or television broadcastingsound reproduction, any computer software, patent, trade ▇▇▇▇, design drawings, designs or modelmodels, planplans, secret formula formulas or processprocesses, or for the use of, or the right to use, in- dustrial, commercial, or scientific equipment or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, arise through a permanent establishment situated situ- ated therein, or performs in that other Party independent personal State services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected con- nected 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party State a permanent establishment establish- ment or a fixed base in connection with which the liability to pay the royalties was incurredin- curred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Party Contracting State in which the permanent per- manent 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 ex- ceeds 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 pay- ments shall remain taxable according to the laws of each Contracting PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 7 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 computer software, patent, trade ▇▇▇▇mark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the recipient and the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 software, cinematograph films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information (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, being a resident of a Contracting PartyState, carries on business in the other Contracting Party State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Party 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 a fixed base. In such case, case the provisions of Article 7 or and Article 14, as the case may be, 15 shall apply. 5. Royalties shall be deemed to arise in a Contracting Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 a fixed base, base then such royalties shall be deemed to arise in the Party State in which the permanent establishment or a fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other 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 PartyState, due regard being had to the other provisions of this Agreement. 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 Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties Royalties described in sub-paragraph a) of paragraph 3 and beneficially owned by a resident of a Contracting State may be taxed only in that State. Royalties described in sub-paragraph b) of paragraph 3 may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 10 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments payment of any kind received as a consideration for the use of, or the right to use, : a) any copyright of literary, artistic or scientific work including cinematograph motion pictures or films, recordings on tape or films or tapes other media used for radio or television broadcasting, broadcasting or other means of reproduction or transmission; b) any computer software, patent, trade ▇▇▇▇trademark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party 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 Party State when the payer is a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party State a permanent establishment or a fixed base in connection with which the liability obligation to pay the royalties was incurred, incurred and such royalties are borne by such that permanent establishment or fixed base, then such royalties shall be deemed to arise in the Party 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party one of the States and paid to a resident of the other Contracting Party State may be taxed in that other PartyState if such resident is the beneficial owner of the royalties. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Partyroyalties, the tax so charged shall not exceed 8 per cent 12 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 cinematographic films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning the use of, or the right to use, industrial, commercial commercial, or scientific experienceequipment. The term “royalties” also includes the gains obtained from the alienation of any of such property or rights which are conditioned upon the productivity or use of them. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting Partyone of the States, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case, cases the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting Party one of the States when the payer is that State itself, a political subdivision, a local authority or a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party one of the States or not, has in a Contracting Party one of the States 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 Party 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 royalties for which they are paid, any reason 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 PartyState, due regard being had to the other provisions of this AgreementConvention. 7. The provisions of this Article shall not apply when the right or property for which the royalties are paid was granted or assigned principally for the purpose of taking advantage of this Article. In the case where one of the States intends to apply this paragraph, the competent authority of that State shall consult in advance with the competent authority of the other State.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such the royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 8 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, cinematographic films and films and tapes for television or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇trademark, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 (Business Profits) or Article 1414 (Independent Personal Services), as the case may be, be shall apply. 5. Royalties shall be deemed to arise in a Contracting Party State when the payer is that State itself, a political subdivision, a local authority or a resident of that PartyState. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 establishment, or fixed base, base then such royalties shall be deemed to arise in the Party 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 recipient 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 PartyState, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting Party State and paid to a resident of the other Contracting Party State may be taxed in that other PartyState. 2. However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyState, but if the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 10 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph cinematography films, or films or tapes used for radio or television broadcasting, any computer software, patent, trade ▇▇▇▇, design or model, 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case, cases the provisions of Article 7 or Article 1415, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting Party State when the payer is a resident of that PartyContracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this Agreement.

Royalties. (1. ) Royalties arising in a Contracting Party State and paid to beneficially owned by a resident of the other Contracting Party State may be taxed in that other PartyContracting State. (2. ) However, such royalties may also be taxed in the Contracting Party State in which they arise and according to the laws of that PartyContracting State, but if the recipient and the beneficial owner of the royalties is a resident of the other Contracting PartyState, the tax so charged shall not exceed 8 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 computer software, patent, trade ▇▇▇▇mark, design or model, plan, secret formula or о г 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 PartyState, carries on business in the other Contracting Party State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Party Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of оf which the royalties are paid a repaid 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 Party State when the payer is a resident of that PartyContracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party State or not, has in a Contracting Party 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 Party 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 PartyState, due regard being had to the other provisions of this AgreementConvention.