TMI BlogRoyalties and fees for technical servicesX X X X Extracts X X X X X X X X Extracts X X X X ..... d in the Contracting State in which they arise, and according to the laws of that State, but if the beneficial owner of the royalties, or fees for technical services, is a resident of the other Contracting State, the tax so charged shall not exceed 15per cent of the gross amount of the royalties or fees for technical services. 3. The term royalties as used in this Article means payments of an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ies or fees for technical services are borne by such permanent establishment or fixed base, then such royalties or fees for technical services shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 7. Where, by reason of special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of roya ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... so charged shall not exceed 22.5 per cent of the gross amount of the royalties or fees for technical services. 3. The term royalties as used in this article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, including cinematograph films or tapes used for radio or television broadcasting, any paten ..... X X X X Extracts X X X X X X X X Extracts X X X X
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