(1) Royalties paid for the use of immovable property or the working of mines, quarries or other natural resources shall be taxable only in the Contracting State in which such property, mines, quarries or other natural resources are situated.
(2) Other royalties arising in a State and paid by a person domiciled in that State to a person domiciled in the other State may be taxed in that other State.
(3) However, such royalties may also be taxed in the State in which they arise and according to the laws of that State. The tax so charged may not exceed 15 per cent of the gross amount of the royalties if the recipient is the beneficial owner of the royalties.
(4) The term "royalties" used in paragraph (2) of 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 works and the use of or right to use cinematographic films and any other audio or visual recordings.
It also covers payments received for the use of any patent, trademark, design or model, plan, or secret formula or process, as well as payments for information concerning industrial, commercial or scientific experience.
Payments for studies of a scientific, geological or technical nature and engineering work with blueprints and related material are also treated as royalties.
(5) Notwithstanding the provisions of paragraph (3), payments of any kind received as a consideration for the use of or the right to use any copyright of literary, artistic or scientific works, including cinematographic works, works recorded for radio or television and any other audiovisual works shall be taxable only in the State in which the recipient is domiciled, if that person is the beneficial owner thereof.
(6) The provisions of paragraphs (2) and (3) shall not apply if the beneficial owner of the royalties being domiciled in one State carries on business in the other State in which the royalties arise, an industrial or commercial activity 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 thereto. In that case, the provisions of Article 10 or Article 23, as the case may be, shall apply.
(7) Royalties shall be deemed to arise in a State when the payer is that State itself, a local authority, a body corporate under public law, or a person domiciled in that State. Where, however, the person paying the royalties, whether he is domiciled in one of the States or not, has in a State a permanent establishment or a fixed base, to which the right or property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated.
(8) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information 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 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 State, due regard being had to the other provisions of this Convention.