Royalties

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..... ent is the beneficial owner of the royalty 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 any copyright of literary, artistic or scientific work including cinematograph films, or tapes for television or broadcasting, any patent .....

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..... , 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 in connection with which the 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 .....

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