TMI BlogROYALTIESX X X X Extracts X X X X X X X X Extracts X X X X ..... of the royalties is a resident of the other Contracting State the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films or films or tapes used ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ch case the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. ( a ) 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 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 th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ich would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. - - statute, statutory provision ..... X X X X Extracts X X X X X X X X Extracts X X X X
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