TMI BlogRoyaltiesX X X X Extracts X X X X X X X X Extracts X X X X ..... e tax so charged shall not exceed 10 per cent of the gross amount of such royalties. 3. The term "royalties" as used in this Article means payment 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 cinematography films, or films or tapes used for radio or television broadcasting, any patent, trad ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... royalties are paid is effectively connected with such permanent establishment or fixed base. In such 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 sub-division, a local authority or a resident of that State. Where, however, the person paying the royalt ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is 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.
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