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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 and paid to a resident of the other Contracting State shall be taxable in that other State.

(2) The term "royalties" as used in this Article means payments of any kind derived as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, including cinematograph films, 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, not constituting immovable property referred to in Article 6, or for any information related with experience acquired in the field of industry, commerce, or science (know-how).

(3) Royalties are deemed to arise in a Contracting 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 Contracting State or not, however, has a permanent establishment in a Contracting 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 Contracting State in which the permanent establishment is situated.

(4) 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 Contracting State, due regard being had to the other provisions of this Convention. In the absence of an agreement between the two States on the applicable provisions, the dispute shall be settled according to the procedure provided in Article 26 of the Convention.