Royalties

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..... sident of the other Contracting State, the tax so charged shall not exceed 15 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 for television or radio bro .....

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..... 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 [itself, a political sub-division, 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 establishmen .....

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..... ch they are paid, exceeds the amount which 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 Agreeme .....

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