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.
ARTICLE 11
Royalties
(1) Royalties which accrue in one of the contracting states and which are paid to a person residing in another contracting state are subject to taxes in the state in which such royalties arise. Royalties may be subject to taxes in the other contracting state.
(2) The term "Royalties" set forth in this article denotes any kind of amounts paid in return of use or the right of use of copyrights that are pertinent to a literary, technical or scientific work, letters patent, trademark, design, model, plan, formula, or secret patterns in return of use or the right of use of any industrial, commercial or scientific equipment or in return of information that are related to industrial, commercial or scientific expertise.