TMI BlogRoyaltiesX X X X Extracts X X X X X X X X Extracts X X X X ..... esident of the other Contracting Party, 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 for television or radio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Article 7 or Article 15, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting Party when the payer is a resident of that Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting Party or not, has in a Contracting Party a permanent establishment or a fixed base in connection with which the liability to pay the royalties wa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The benefits of this Article shall not be available if the main purpose or one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the royalties are paid is to take advantage of this Article by means of that creation or assignment.
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