Common use of Royalties Clause in Contracts

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 15 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) the use of, or the right to use, any patent, trade ▇▇▇▇, 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 of the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment 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 paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of in that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he the payer is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer payer, and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. Howevershall, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 15 per cent of the gross amount of the royaltiesbe taxable only in that other State. 32. The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or discs for radio or television broadcasting), any patent, trade ▇▇▇▇mark, design or model, computer programme, 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. 43. The provisions of paragraphs paragraph 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 54. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection or a fixed base with which the obligation 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 establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 65. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties arising in a Contracting State may also be taxed in the that Contracting State in which they arise, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or any patent, trade ▇▇▇▇mark, design or model, plan, or 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that Contracting State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed exceed: (a) 10 per cent of the gross amount of the royalties referred to in paragraph 3 (a) ; (b) 15 per cent of the gross amount of the royaltiesroyalties referred to in paragraph 3 (b) . 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) the use of, or the right to use, any patent, know-how, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of any 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, use any copyright of literary or artistic work including 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itselfState, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne brone by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 7. Royalties derived by a resident of China which are subjected to film hire duty under the Cinematograph Film-Hire Duty Act in Malaysia shall not be liable to Malaysian tax to which this Agreement applies.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, of or the right to use, industrial, commercial, or scientific equipment, or for use 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, 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 a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

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

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including computer software, cinematograph films, or films, tapes or discs used for radio or television broadcasting, any 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 per cent eight (8) percent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including computer software, cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, industrial, commercial, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 7. The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the royalties are paid to take advantage of this Article by means of that creation or assignment.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws law of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 15 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: (a) the use of, or the right to use, any 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment 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 paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) 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 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1. ) Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may be taxed in that other State. (2. ) However, such the royalties referred to in paragraph 1 may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, royalties the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any 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, use any industrial, commercial, or scientific equipment, equipment or for information concerning industrial, commercial or scientific experience;. (b4) 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5. ) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6. ) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1. ) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2. ) However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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 kind, whether periodical or not, and however described or computed, to the extent to which they are made as a consideration for: (a) the use of, or the right to use, any copyright (including the use of or the right to use any literary, dramatic, musical, or artistic works, sound recordings, films, broadcasts, cable programmes, or typographical arrangements of published editions), patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or any copyright of scientific worktrade-mark, or for the use of, other like property or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience;right; or (b) the use of, or the right to use, cinematograph filmsany industrial, scientific or tapes for radio commercial equipment; or c) knowledge or television broadcastinginformation concerning industrial, any copyright of literary commercial or artistic workscientific experience. (4. ) The provisions of paragraphs 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. (5. ) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or person who is a resident of that State. Where, however, the person paying such the royalties, whether he the person is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such the royalties are borne by such deductible in determining the income, profits or gains attributable to that permanent establishment, then such the royalties shall be deemed to arise in the State in which the permanent establishment 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may shall be taxed taxable only in that other Contracting State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 15 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or any patent, trade ▇▇▇▇, design or model, plan, or 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. 43. The provisions of paragraphs paragraph 1 and 2 of this Article shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 of this Convention shall apply. 54. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that Contracting State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1. ) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2. ) However, such the royalties mentioned in sub-paragraph a) of paragraph 3 may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of these limitations. (3. ) The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, ,: a) any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific workcomputer software, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience; (b) the use ofany copyright of literary, artistic or the right to use, scientific work including cinematograph films, films and films or tapes for television or radio or television broadcasting, any copyright of literary or artistic work. (4. ) The provisions of paragraphs 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. (5. ) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability 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 State in which the permanent establishment 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

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

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) the he use of, or the right to use, any 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 he use of, or the right to use, cinematograph films, or tapes for radio or television broadcasting, any copyright of literary or artistic work. 4. The provisions of paragraphs 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment 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 paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State One Side and paid to a resident of the other Contracting State Other Side may be taxed in that other StateOther Side. 2. However, such royalties may also be taxed in the Contracting State Side in which they arise, arise and according to the laws of that StateSide, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the Other Side, the tax so charged shall not exceed 15 per cent 7% of the gross amount of the royalties. The competent authorities of both Sides shall by mutual agreement settle the mode of application of this limitation. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, the copyright of literary, artistic or scientific works including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇trademark, 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, 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 of this Article shall not apply of if the beneficial owner of the royalties, being the Government of One Side, a local authority thereof or a resident of a Contracting Statethat Side, carries on business in the other Contracting State Other Side in which the royalties arise through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such that permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State One Side when the payer is the Government of that State itself, a political subdivisionSide, a local authority or a statutory body thereof, thereof or a resident of that StateSide. WhereHowever, however, where the person paying such the royalties, whether he is the Government of One Side, a local authority thereof or a resident of a Contracting State that Side or not, has in a Contracting State that Side a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such that permanent establishment, then such royalties shall be deemed to arise in the State Side in which the permanent establishment 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 paidexceeds, 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 a case, the excess part of the payments shall remain taxable according to the laws of each Contracting StateSide, but due regard being shall still be had to the other provisions of this AgreementArrangement.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may shall be taxed taxable only in that other Contracting State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 15 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or any patent, trade ▇▇▇▇, design or model, plan, or 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. 43. The provisions of paragraphs paragraph 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 54. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that Contracting State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State Party and paid to a resident of the other Contracting State Party may be taxed in that other StateContracting Party. 2. However, such royalties arising in a Contracting Party may also be taxed in the that Contracting State in which they arise, and Party according to the laws of that StateContracting Party, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting Party, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work, any 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 of if the beneficial owner of the royalties, being a resident of a Contracting StateParty, carries on business in the other Contracting State Party in which the royalties arise through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State Party when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that StateParty. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State Party or not, has in a Contracting State Party a permanent establishment in connection with which the obligation liability 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 State Party in which the permanent establishment 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 paidroyalties, 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 StateParty, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State Party and paid to a resident of the other Contracting State Party may be taxed in that other StateParty. 2. However, such royalties may also be taxed in the Contracting State Party in which they arise, arise and according to the laws of that StateParty, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting Party, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, 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 of if the beneficial owner of the royalties, being a resident of a Contracting StateParty, carries on business in the other Contracting State Party in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State Party when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that StateParty. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State Party or not, has in a Contracting State Party a permanent establishment in connection with which the obligation liability 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 State Party in which the permanent establishment 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 paidexceeds, 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 a case, the excess part of the payments shall remain taxable according to the laws of each Contracting StateParty, due regard being had to the other provisions of this Agreement.

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

Royalties. 1. Royalties arising in a Contracting State territory and paid to a resident of the other Contracting State territory may be taxed in that other Stateterritory. 2. However, such royalties may also be taxed in the Contracting State territory in which they arise, arise and according to the laws of in force in that Stateterritory, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other territory, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes for television or radio broadcasting, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, 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 of if the beneficial owner of the royalties, being a resident of a Contracting Stateterritory, carries on business in the other Contracting State territory in which the royalties arise through a permanent establishment situated therein, or performs in that other 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 establishmentestablishment or fixed base. In such a case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State territory when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that Stateterritory. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State territory or not, has in a Contracting State territory a permanent establishment or a fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State territory in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, 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 in force in each Contracting Stateterritory, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties arising in a Contracting State may also be taxed in the that Contracting State in which they arise, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, or 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that Contracting State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State Party and paid to a resident of the other Contracting State Party may be taxed in that other StateContracting Party. 2. However, such royalties may also be taxed in the Contracting State Party in which they arise, arise and according to the laws of that StateContracting Party, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting Party, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes for radio or television broadcasting, any patent, trade ▇▇▇▇, design or model, plan, or 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 of if the beneficial owner of the royalties, being a resident of a Contracting StateParty, carries on business in the other Contracting State Party in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State Party when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that StateContracting Party. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State Party or not, has in a Contracting State Party a permanent establishment in connection with which the obligation liability 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 State Contracting Party in which the permanent establishment 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 paidroyalties, 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 StateParty, due regard being had to the other provisions of this Agreement.

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

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematography films, any patent, software, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability 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 State in which the permanent establishment 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability 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 State in which the permanent establishment 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1. ) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2. ) However, such the royalties mentioned in sub-paragraph a) of paragraph 3 may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of these limitations. (3. ) The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, ,: a) any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or any copyright of scientific workcomputer software, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience; (b) the use ofany copyright of literary, artistic or the right to use, scientific work including cinematograph films, films and films or tapes for television or radio or television broadcasting, any copyright of literary or artistic work. (4. ) The provisions of paragraphs 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. (5. ) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability 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 State in which the permanent establishment 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

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

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

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 15 exceed: (a) in the case of Laos: -5 per cent of the gross amount of the royalties; (b) in the case of China: -10 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of the above limitations. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films or films or tapes for radio or television broadcasting, any 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itself, a political subdivisionContracting State, a local authority or a statutory body thereof, thereof or a resident of that Contracting State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties arising in a Contracting State may also be taxed in the that Contracting State in which they arise, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or any patent, trade ▇▇▇▇mark, design or model, plan, or 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that Contracting State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films, and films or tapes for radio or television broadcasting), any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or any copyright of scientific work, other like right or for the use of, or the right to use, industrial, commercial, or scientific equipmentproperty, or for information (know-how) 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 paidpaid exceeds, having regard to the usefor whatever reason, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner of the royalties in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 7. No relief shall be available under this Article if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the royalties are paid to take advantage of this Article by means of that creation or assignment.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work, including cinematograph films, any 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 paragraph 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, incurred and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties, royalties the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and recordings for radio or television broadcasting, any patent, know-how, 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, commercial or scientific equipment, or for information concerning industrial, commercial 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itselfContracting State, a political subdivision, a local authority or a statutory body thereof, thereof or a resident of that Contracting State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1. ) Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may be taxed in that other State. (2. ) However, such the royalties referred to in paragraph 1 may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, royalties the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, use any industrial, commercial, or scientific equipment, equipment or for information concerning industrial, commercial or scientific experience;. (b4) 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5. ) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6. ) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, royalties the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes used for radio or television broadcasting, any 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, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he or she is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability 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 State in which the permanent establishment 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 paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this the Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is recipient's the beneficial owner of the royalties, the tax so charged shall not exceed 15 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) the use of, or the right to use, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, 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 (1) and 2 (2) shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise rise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such royalties, whether he is a resident of a Contracting State or not, not has in a Contracting State a permanent establishment in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment 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 paid, having regard to the use, right or of information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other the first-mentioned State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the The tax so charged shall not exceed 15 per cent (5) five percent of the gross amount of the royalties. 32. The term "“royalties" ” as used in this Article means means, payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and computer software, any patent, trade ▇▇▇▇, design or model, plan, secret formula formula, or process, or any copyright of scientific work, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, equipment or for information concerning industrial, commercial or scientific experience; 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 workknow-how). 43. The provisions of paragraphs paragraph 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, the provisions of Article 7 and 14 shall apply, as the case may be. 54. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 65. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, then the tax so charged shall not exceed 15 per cent of the gross amount of the royalties. 3. The term "“ royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to useuse any copy right of literary, artistic, or scientific work including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, State carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, therein or performs in that other State independent personal services from a fixed base situated therein and the right or of property in respect of which the royalties are paid is effectively directly connected with such permanent establishmentestablishment or fixed base or with: (a) such permanent establishment or fixed base; or with (b) business activities referred to under (c) or paragraph 1 of Article 7. In such a case, case the provisions of Article 7 or 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, thereof or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, or fixed base then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had given to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws law of that State, but if the recipient is the beneficial owner of the royalties, royalties the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) 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 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) the he use of, or the right to use, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment 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 paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 15 exceed: (a) 5 per cent of the gross amount of the royaltiesroyalties which are paid for the use of, or the right to use, industrial, commercial or scientific equipment; (b) 8 per cent of the gross amount of the royalties in all other cases. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films or films or tapes used for radio or television broadcasting), any patent, trade ▇▇▇▇, design or 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 of this Article shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, case the provisions of Article 7 or Article 14 of this Convention, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that Contracting State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematographic films and films, tapes and other means of image or sound reproduction) any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, process or any copyright of scientific workother intangible property, or for the use of, or the right to use, industrial, commercial, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment 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 paidexceeds, 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 a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 7. The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the rights in respect to which the royalties are paid to take advantage of this Article by means of that creation or assignment.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 7.5 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or discs for radio or television broadcasting), any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information (know-how) 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 paragraph 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment 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 paidpaid 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 a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. Royalties shall be deemed to arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the royalties, whether that person is a resident of a Contracting State or not, has in a Contracting State a permanent establishment with which the right or property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment is situated. 7. No relief shall be available under this Article if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the royalties are paid to take advantage of this Article by means of that creation or assignment.

Royalties. (1. ) Royalties arising in a Contracting State which are derived and paid to beneficially owned by a resident of the other Contracting State may be taxed in that other State. (2. ) However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws law of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. (3. ) The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films, and films or tapes for radio or television broadcasting), any 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, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience;. (b4) the use of, or the right to use, cinematograph films, or tapes for radio or television broadcasting, any copyright of literary or artistic work. 4. The provisions of paragraphs 1 (1) and 2 (2) of this Article shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business has in the other Contracting State in which the royalties arise through a permanent establishment 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 establishmentconnected. In such a case, the provisions of Article 7 shall apply. (5. ) Royalties shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where. (6) Notwithstanding the provisions of paragraph (5) of this Article, however, where the person paying such payer of the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurredincurred and which bears the royalties, and such royalties are borne by such permanent establishment, then such the royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 6. (7) Where, by reason of owing to a special relationship between the payer and the beneficial owner person deriving the royalties or between both of them and some other person, the amount of the royalties paidpaid exceeds, having regard to the usefor whatever reason, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner paid in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a that case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties arising in a Contracting State may also be taxed in the Contracting that State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including software and cinematograph films, any 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 (know-how) 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 paragraph 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein or performs in that other State independent personal services from a fixed base situated therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment 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 paidpaid 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 a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. No relief shall be available under this Article if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the royalties are paid to take advantage of this Article by means of that creation or assignment.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties arising in a Contracting State may also be taxed in the that Contracting State in which they arise, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or any patent, trade ▇▇▇▇mark, design or model, plan, or 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that Contracting State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

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

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

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including software, cinematograph films and films or tapes for radio or television broadcasting, any patent, trade ▇▇▇▇, design or model, plan, or 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 workexperi- ence. 4. The provisions of paragraphs 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, situat- ed therein and the right or property in respect of which the royalties are paid is effectively effec- tively connected with such permanent establishment. In such a case, case the provisions of Article Ar- ticle 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that Contracting State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent per- manent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties ▇▇▇- alties shall be deemed to arise in the Contracting State in which the permanent establishment estab- lishment is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having hav- ing regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence ab- sence of such relationship, the provisions of this Article shall apply only to the last-last- mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions provi- sions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties arising in a Contracting State may also be taxed in the Contracting that State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇trademark, 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, commercial or scientific equipment, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, incurred and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may shall be taxed taxable only in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 15 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work, including cinematograph films and recordings for radio and television broadcasting, any patent, know how, computer programmes, trade ▇▇▇▇, design or model, plan, secret formula or process, or any copyright of for information concerning industrial, commercial or scientific work, experience or for the use of, or the right to use, industrial, commercial, 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. 43. The provisions of paragraphs paragraph 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment establishment, or performs 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 establishmentestablishment or fixed base. In such a case, case the provisions of Article Articles 7 or 15, as the case may be, shall apply. 54. Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itselfContracting State, a political subdivisionsubdivision of that State, a local authority or a statutory body thereof, thereof or a resident of that Contracting State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 65. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable taxable, according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, and films or tapes for radio or television broadcasting, any patent, computer software, 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, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner of the royalties in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties arising in a Contracting State may also be taxed in the that Contracting State in which they arise, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or any patent, trade ▇▇▇▇, design or model, plan, or 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that Contracting State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1. ) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2. ) However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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 kind, whether periodical or not, and however described or computed, to the extent to which they are made as a consideration for: (a) the use of, or the right to use, any copyright (including the use of or the right to use any literary, dramatic, musical, or artistic works, sound recordings, films, broadcasts, cable programmes, or typographical arrangements of published editions), patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or any copyright of scientific worktrade-▇▇▇▇, or for the use of, other like property or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience;right; or (b) the use of, or the right to use, cinematograph filmsany industrial, scientific or tapes for radio commercial equipment; or c) knowledge or television broadcastinginformation concerning industrial, any copyright of literary commercial or artistic workscientific experience. (4. ) The provisions of paragraphs 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. (5. ) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or person who is a resident of that State. Where, however, the person paying such the royalties, whether he the person is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such the royalties are borne by such deductible in determining the income, profits or gains attributable to that permanent establishment, then such the royalties shall be deemed to arise in the State in which the permanent establishment 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State Party and paid to a resident of the other Contracting State Party may be taxed in that other StateParty. 2. However, such royalties may also be taxed in the Contracting State Party in which they arise, arise and according to the laws of that StateParty, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting Party, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, 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 of if the beneficial owner of the royalties, being a resident of a Contracting StateParty, carries on business in the other Contracting State Party in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State Party when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that StateParty. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State Party or not, has in a Contracting State Party a permanent establishment in connection with which the obligation liability 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 State Party in which the permanent establishment 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 paidroyalties, 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 StateParty, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may shall be taxed taxable only in that other State. 2. However, State if such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient resident is the beneficial owner of the royalties, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any 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. 43. The provisions of paragraphs paragraph 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 5. Royalties shall be deemed to arise in a Contracting State when the payer is the State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties arising in a Contracting State may also be taxed in the that Contracting State in which they arise, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes used for radio or television broadcasting, or any patent, trade ▇▇▇▇, design or model, plan, or 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that Contracting State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1. ) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2. ) However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. (3. ) The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or discs for radio or television broadcasting), any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience;. (b4) 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, the provisions of Article 7 shall apply. (5. ) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability 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 State in which the permanent establishment 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may shall be taxed taxable in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes for television or radio broadcasting, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1. ) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2. ) However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. (3. ) The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or 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;. (b4) 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. (5. ) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay indebtedness on which the royalties are paid was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment is situated. (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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1. ) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2. ) However, such the royalties referred to in paragraph 1 may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any 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, any industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience;. (b4) 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, the provisions of Article 7 shall apply. (5. ) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability 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 State in which the permanent establishment 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties arising in a Contracting State may also be taxed in the that Contracting State in which they arise, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or any patent, trade ▇▇▇▇, design or model, plan, or 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that Contracting State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any 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 (know-how) 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he that person is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay right or property in respect of which the royalties was incurredare paid is effectively connected, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment is situated. 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 paidpaid 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 a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 7. No relief shall be available under this Article if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the royalties are paid to take advantage of this Article by means of that creation or assignment.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any 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, experience and any copyright of literary or artistic work. 4. The provisions of paragraphs 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise a business through a permanent establishment situated therein, or performs in that other State independent personal services and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or services. In such a case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that Contracting State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment 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 paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement. 7. Royalties derived by a resident of the Czech Republic, being royalties that, as film rentals, are subject to the cinematograph film-hire duty in Malaysia, shall not be liable to Malaysian tax.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed exceed: (a) 10 per cent of the gross amount of the royalties for the use of, or the right to use, any copyright of literary, artistic or scientific work, or for the use of, or the right to use, industrial, commercial or scientific equipment, (b) 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work, including software, motion pictures, live broadcasting, films, tapes, other means of the use or reproduction in connection with radio and television broadcasting and other means of image or sound reproduction, patent, trade ▇▇▇▇, design or model, plan, secret formula or process, process or any copyright of scientific workother intangible property, or for the use of, or the right to use, industrial, commercial, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this 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 to which the royalties are paid to take advantage of this Article by means of that creation or assignment.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties arising in a Contracting State may also be taxed in the that Contracting State in which they arise, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 5 per cent of the gross amount of the royalties. 3. Notwithstanding the provisions of paragraph 2, royalties arising in a Contracting State shall be taxable only in the other Contracting State if the royalties are beneficially owned by a resident of that other Contracting State for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films. 4. The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or any patent, trade ▇▇▇▇, design or model, plan, or secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, industrial, commercial, 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. 45. The provisions of paragraphs 1 1, 2 and 2 3 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 56. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that Contracting State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 67. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State, if such resident is the beneficial owner of the royalties. 2. However, such Such royalties may also be taxed in the Contracting State in which they arise, and according to the laws law of that State, but if the recipient is the beneficial owner of the royalties. However, the tax so charged shall not exceed exceed a) 15 per cent of the gross amount of the royalties, where the royalties are paid by an enterprise registered with and engaged in preferred areas of activities, and also royalties in respect of cinematographic films or tapes for television or broadcasting, and royalties for the use of, or the right to use, any copyright of literary, artistic or scientific work; and b) in all other cases, 25 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for:consideration (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work; b) for the use of, or the right to use, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or ; c) 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 of if the beneficial owner recipient of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State professional services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or authority, a statutory body thereof, public community or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 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 a that case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that the State, but if the recipient is recipient, being the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including software, cinematograph films, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, 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 paragraph 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability 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 State in which the permanent establishment 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1. ) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2. ) However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 7.5 per cent of the gross amount of the royalties. (3. ) The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) con­ sideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films, tapes or discs for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, of or the right to use, use industrial, commercial, commercial or scientific equipment, equipment or for information concerning industrial, commercial or scientific experience;. (b4) the use of, or the right to use, cinematograph films, or tapes for radio or television broadcasting, any copyright of literary or artistic work. 4. The provisions of paragraphs 1 (1) and 2 (2) shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. (5. ) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. (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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 eight per cent (8%) of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematography films and films or tapes for television or radio broadcasting or broadcasting by satellite, cables, optical fibres or similar technology used for broadcasting, magnetic tapes, discs or laser discs, computer software, any 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, commercial or scientific equipment, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting Con- tracting State may be taxed in that other State. 2. However, such royalties arising in a Contracting State may also be taxed in the Contracting that State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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 re- ceived as a consideration for: (a) for the use of, or the right to use, any copyright of liter- ary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting or any other means of image or sound transmission or reproduction, and for the use or the right to use of any software, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, industrial, commercial, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment estab- lishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, cases the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he that person is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay right or property in respect of which the royalties was incurredare paid is effectively connected, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment is situated. 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 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 received, as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a authority, statutory body thereof, or a resident of that State. Where, however, the person paying such royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, establishment then such royalties shall be deemed to arise in the State in which the permanent establishment 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, person the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article article shall apply only to the last-mentioned amount. In such a case, case the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

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

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including software and cinematograph films, any patent, trade ▇▇▇▇, drawing, 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, equipment or for information concerning industrial, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such the permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in Subject to the provisions of paragraph 2 of this Article, royalties derived and beneficially owned by a resident of a Contracting State and shall be taxable only in that State. 2. Where royalties paid to by a company which is a resident of a Contracting State are beneficially owned by a company which is a resident of the other Contracting State may be taxed in that other State. 2. Howeverand controls directly or indirectly more than 50 per cent of the voting power of the company paying the royalties, such those royalties may also may, notwithstanding the provisions of paragraph 1 of this Article, be taxed in the Contracting State in which they arise, and according to the laws of that first-mentioned State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films, and films or tapes for radio or television broadcasting), any 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, 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 of this Article shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business has in the other Contracting State in which the royalties arise through a permanent establishment 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. In such a case, the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when Any provision of the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such royalties, whether he is a resident law of a Contracting State which requires royalties paid by a company to be left out of account as a deduction in computing the company's taxable profits because they are treated as a dividend or not, has distribution shall not operate in relation to royalties paid to a resident of the other Contracting State a permanent establishment in connection with which State. The preceding sentence shall not however apply if the obligation right or property giving rise to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in created or assigned mainly for the State in which the permanent establishment is situated. 6. Where, by reason purpose of a special relationship between the payer and the beneficial owner or between both taking advantage of them and some other person, the amount of the royalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreementand not for bona fide commercial reasons.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of or which the royalties are paid is effectively connected with (a) such permanent establishmentestablishment or fixed base or with (b) business activities referred to under (c) of paragraph 1 of Article 7. In such a case, case the provisions of Article 7 or Article 15, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, not has in a Contracting State a permanent establishment or fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, 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 he excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes and other means of image or sound reproduction for radio or television broad-casting, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or any copyright of scientific workfor transmission by satellite, cable, optic fibre or similar technology, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience; (b) . Notwithstanding the provisions of Article 13, the term “royalties” also includes payments derived from the alienation of any such right or property which are contingent on the productivity or use of, or the right to use, cinematograph films, or tapes for radio or television broadcasting, any copyright of literary or artistic workthereof. 4. The provisions of paragraphs 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State States or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. (1. ) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2. ) However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. (3. ) The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes for television or radio broadcasting, any 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, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience;. (b4) 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. (5. ) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, it arises and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information (know- how) 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 paragraph 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 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 paidpaid 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 a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 7. No relief shall be available under this Article if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the royalties are paid to take advantage of this Article by means of that creation or assignment.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or other means for radio or television broadcasting), any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection or a fixed base with which the obligation 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 establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 6. Where, by reason reas on 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned last -mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the a beneficial owner of the royalties, the tax so charged shall not exceed 15 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability 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 State in which the permanent establishment 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may shall be taxed taxable only in that other State. 2. However, if such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient resident is the beneficial owner of the royalties, the tax so charged shall not exceed 15 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, 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. 43. The provisions of paragraphs paragraph 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a 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 State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection or a fixed base with which the obligation to pay the royalties was incurred, incurred and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 65. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other the first mentioned State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the The tax so charged shall not exceed 15 per cent 5% five percent 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or discs for radio or television broadcasting), any 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. 43. The provisions of paragraphs 1 and 2 paragraph (1) shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment or fixed base situated therein or performs in that other state independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, the provisions of Article 7 (7) or (14) shall apply. 54. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection or fixed base with which the obligation to pay right, property in respect of which the royalties was incurredare paid is effectively connected, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 65. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

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

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or discs for radio or television broadcasting), any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability 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 State in which the permanent establishment 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other StateState if such resident is the beneficial owner of the royalties. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 exceed: (a) 5 per cent of the gross amount of the royaltiesroyalties if the beneficial owner is an enterprise of that other Contracting State; (b) 10 per cent of the gross amount of the royalties in all other cases. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes for television or radio broadcasting, any 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 paragraph 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State Sate or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties arising in a Contracting State may also be taxed in the that Contracting State in which they arise, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 5 per cent of the gross amount of the royalties. 3. Notwithstanding the provisions of paragraph 2, royalties arising in a Contracting State shall be taxable only in the other Contracting State if the royalties are beneficially owned by a resident of that other Contracting State for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films. 4. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or any patent, trade ▇▇▇▇mark, design or model, plan, or secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, industrial, commercial, 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. 45. The provisions of paragraphs 1 1, 2 and 2 3 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 shall apply. 56. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that Contracting State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 67. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may be taxed taxable in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, 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 of this Article shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or discs for radio or television broadcasting), any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he that person is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay right or property in respect of which the royalties was incurredare paid is effectively connected, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment is situated. 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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 per cent exceed: (a) in the case of royalties as defined in paragraph 3 subparagraph (a), 10% of the gross amount of such royalties; and (b) in the case of royalties as defined in paragraph 3 subparagraph (b), 8% of the gross amount of such royalties. 3. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration forconsideration: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or ; or (b) for the use of, or the right to use, industrial, commercial, 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 of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 6. Where, Where by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. 1. Royalties arising in a Contracting State territory and paid to a resident of the other Contracting State territory may be taxed in that other Stateterritory if such resident is the beneficial owner of the royalties. 2. However, such royalties may also be taxed in the Contracting State territory in which they arise, it arises and according to the laws of that Stateterritory, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other territory, the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph-films, any 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 of if the beneficial owner of the royalties, being a resident of a Contracting Stateterritory, carries on business in the other Contracting State territory in which the royalties arise through a permanent establishment situated therein, or performs in that other 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 establishmentestablishment or fixed base. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State territory when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that Stateterritory. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State territory or not, has in a Contracting State territory a permanent establishment or a fixed base in connection with which the obligation indebtedness on which the liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State territory in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article article shall apply only to the last-mentioned amount. In such a that case, the excess part of the payments shall remain taxable according to the laws of each Contracting Stateterritory, due regard being had to the other provisions of this Agreement. 7. The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the royalties are paid to take advantage of this Article by means of that creation or assignment.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, However such royalties may also be taxed in the Contracting State in which they arise, arise and according to the laws of that State, but if the recipient is the beneficial owner of the royaltiesroyalties is a resident of the other Contracting State, the tax so charged shall not exceed 15 10 per cent of the gross amount of the royalties. 3. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of paragraph 2. 4. The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any 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. 45. The provisions of paragraphs 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. 56. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the royalties was incurred, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 67. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

Royalties. 1. Royalties arising in derived and beneficially owned by a resident of a Contracting State and paid to a resident of the other Contracting State may shall be taxed taxable only in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 15 per cent of the gross amount of the royalties. 3. The term "„royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) the for use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films, and films or tapes for radio or television broadcasting), any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, 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. 43. The provisions of paragraphs 1 and 2 paragraph (1) of this Article shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business has in the other Contracting State in which the royalties arise through a permanent establishment 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. In such a case, the provisions of Article 7 8 shall apply. 54. Royalties shall be deemed to arise in Any provision of the law of a Contracting State when 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 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 and beneficially owned by a company which is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such royalties, whether he is a resident of a other Contracting State where – (a) the same persons participate directly or not, has indirectly in a Contracting State a permanent establishment in connection with which the obligation to pay management or control of the company paying the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise the company beneficially owning the royalties; and (b) more than 50 percent of the voting power in the company beneficially owning the royalties is controlled directly or indirectly by a person or persons resident in the contracting State in which the permanent establishment company paying the royalties is situatedresident. 65. 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 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-last- mentioned amount. In such a that case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement.

Royalties. (1. ) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. (2. ) However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, royalties is a resident of the other Contracting State the tax so charged shall not exceed 15 5 per cent of the gross amount of the such royalties. (3. ) The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films, and films or tapes for radio or television broadcasting), any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information (know-how) concerning industrial, commercial or scientific experience;. (b4) the use of, or the right to use, cinematograph films, or tapes for radio or television broadcasting, any copyright of literary or artistic work. 4. The provisions of paragraphs 1 (1) and 2 (2) of this Article shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such a case, case the provisions of Article 7 of this Convention shall apply. (5. ) Royalties shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation liability 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 State in which the permanent establishment 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 paidpaid 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 a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. (7) No relief shall be available under this Article if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the royalties are paid to take advantage of this Article by means of that creation or assignment.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other the first mentioned State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the The tax so charged shall not exceed 15 per cent (5) five percent 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: (a) for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or discs for radio or television broadcasting), any patent, trade ▇▇▇▇mark, design or model, plan, secret formula or process, or any copyright of scientific work, or for the use of, or the right to use, 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. 43. The provisions of paragraphs paragraph 1 and 2 shall not apply of if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 54. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that State. Where, however, the person paying such the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection or fixed base with which the obligation to pay right, property in respect of which the royalties was incurredare paid is effectively connected, and such royalties are borne by such permanent establishmentestablishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated.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 paidroyalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.