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CHAPTER 1 - General Provisions
CHAPTER 2 - Taxation of Income
CHAPTER 3 - Inheritance Tax
CHAPTER 4 - Registration Fees Other than Inheritance Tax-Stamp Duty
CHAPTER 5 - Administrative Assistance
CHAPTER 6 - Special Provisions
CHAPTER 7 - Transitional Provisions
CHAPTER 8 - Final Provisions
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 Member State and paid to a resident of another Member State may be taxed in that other State.

(2) However, such royalties shall also be taxed in the Member State in which they arise if the law of that State so provides, but the tax so charged shall not exceed 15 % 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 and recordings for radio and televised transmission, or transmissions via satellite, cable, optic fiber or similar technology used for transmission intended for the public, tapes, floppies, laser disks (software), any patent, trademark, design or model, plan, secret formula or process as well as for the use of, or the right to use, any industrial, commercial or scientific equipment or for any information related with experience acquired in the field of industry, commerce, agriculture or science (know-how).

(4) The provisions of paragraphs (1) and (2) of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Member State, carries on an industrial or commercial activity in the other Member State in which the royalties arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected therewith. In such case the provisions of Article 8 or Article 15 of this Regulation, as the case may be, shall apply.

(5) The royalties are deemed to arise in a Member State in case the payer is that State itself, a local authority thereof, or another resident of that State. In case the payer of the royalties, whether a resident of a member State or not, however, has a permanent establishment in a Member State for which the contract giving rise to the payment of the royalties has been entered and which as such incurs the charge thereof, such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated.

(6) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some third parties, the amount of the royalties, having regard to the service for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of similar relationships, 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 in accordance with the laws of each Member State, due regard being had to the other provisions of this Regulation.