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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.



(1) Royalties arising in a Contracting State may be taxable in that State.

(2) The term "royalties" as used in this Article means payments of any kind as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, any patent, trade mark, design or model, plan secret formula or process of for the use of the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience.

(3) The term "royalties" as used in this Article shall exclude rentals and other income in respect of cinematographic films. Such rentals, and income shall, for the purpose of this Convention, be considered the profits from business.