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CHAPTER I - Income Tax
CHAPTER II - Registration Fees and Stamp Duties
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 paid for the enjoyment of immovable property or for the operation of mines, quarries or other natural resources shall be taxable only in that Contracting State where such property, mines, quarries or other natural resources are situated.

(2) Copyright as well as earnings or fees (royalties) from the sale or use of operating  licenses for patents, trademarks, secret formulas and processes, that are paid in one of the Contracting States, to a person having his fiscal domicile in the other Contracting State, shall be taxable only in the last mentioned that State.

(3) To be treated as royalties referred to in paragraph (2) of this Article are sums paid for hiring or for the right to use cinematographic films, similar remuneration for the supply of information related to experiments in the industrial, commercial or scientific field and hiring rights for the use or the right to use industrial, commercial or scientific equipment subject to cases where this equipment has an immovable nature, in which case paragraph (1) of this Article shall apply.

(4) If a royalty is higher than the intrinsic and normal value of the rights for which it is paid, the exemption provided for under paragraphs (2) and (3) of this Article shall only apply to the part of this royalty which corresponds to this intrinsic and normal value.

(5) The provisions of paragraphs (2) and (3) of this Article shall not apply where the recipient of the royalty or other remuneration, maintains in the Contracting State from where the income arises, a permanent establishment or a fixed place of business used for the exercise of independent professional services or any other independent activity and where this royalty or other remuneration is attributed to that permanent establishment or that fixed place of business. In such a case, the said State shall have the right to tax this income as per its laws.