TMI BlogArticle 12 - RoyaltiesX X X X Extracts X X X X X X X X Extracts X X X X ..... Exception of this para 1 of Article 12 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 establi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing had to the other provisions of this Convention. [ Para 4 of Article 12 ] Definition of Royalties Royalties means payments of any kind received as a consideration for the use of or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade mark, design or model, plan, secret formula or process ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... alties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. [ Para 2 of Article 12 ] Exception of Para 1 and 2 of Article 12 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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. [ Para 5 of the Article 12 ] Definit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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