Common use of ROYALTIES AND FEES FOR TECHNICAL SERVICES Clause in Contracts

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services the tax so charged shall not exceed: a) in the case of royalties 10 per cent of the gross amount of such royalties, b) in the case of fees for technical services 7.5 per cent of the gross amount of such fees. (2) 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 cinematographic films and films or tapes for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerial, technical or consultancy nature rendered in the Contracting State of which the payer is a resident. (4) The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to make the payments was incurred, and the payments are borne by that permanent establishment or fixed base, then the royalties or fees for technical services shall be deemed to arise in the Contracting 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 other person, the amount of the royalties or fees for technical services paid exceeds, for whatever reason, 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services the tax so charged shall not exceed: a) a. in the case of royalties 10 per cent of the gross amount of such royalties,; b) b. in the case of fees for technical services 7.5 per cent of the gross amount of such fees. (2) 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 cinematographic payments of any kind in respect of motion picture films and films works on film, tape or tapes other means of reproduction for radio or television broadcasting), any patent, trade xxxxmark, design or model, plan, secret formula or process, process or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "“fees for technical services" ” as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerial, technical or consultancy nature rendered in the Contracting State of which the payer is a resident. (4) 5. The provisions of paragraph 1 of this Article 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) 6. Royalties and or fees for technical services servies shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to make the payments payment was incurred, and the payments such royalties or fees for technical services are borne by that permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceeds, for whatever reason, 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services services, the tax so charged shall not exceed: a) in the case of royalties 10 per cent exceed 15 percent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent services. The competent authorities of the gross amount Contracting States shall by mutual agreement settle the mode of such feesapplication of this limitation. (2) 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 cinematographic films and cinematography films, or films or tapes used for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, equipment or for information concerning industrial, commercial or scientific experience. (3) 4. The term "“fees for technical services" ” as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature rendered in the Contracting State of which the payer is a resident. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, or a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceedsservices, having regard to the use, right, information or contract for whatever reasonwhich 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services the tax so charged shall not exceed: a) in the case of royalties 10 exceed 20 per cent cent. of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) 3. The term "royalties" royalties " as used in this Article 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 cinematographic cinematograph films, films and films or video tapes for use in connection with television or tapes for use in connection with radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "" fees for technical servicesservices " as used in this Article article means payments of any kind to any person, other than payments to an employee of the person making the paymentspayments and to any individual for independent personal services mentioned in article 15, in consideration for any services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed basebase or with business activities referred to under (c) of paragraph 1 of article 7. In such case, the provisions of Article article 7 or Article 14article 15, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceedsservices, having regard to the use, right or information for whatever reasonwhich 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 Contracting State, due regard being had to the other provisions of this AgreementConvention.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services services, the tax so charged shall not exceed: a) a. in the case of royalties 10 per cent percent of the gross amount of such royalties,; b) b. in the case of fees for technical services 7.5 per cent percent of the gross amount of such fees. (2) 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 cinematographic films and cinematograph films, or films or tapes used for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, process or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, equipment or for information concerning industrial, commercial or scientific experience. (3) 4. The term "“fees for technical services" ” as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the paymentspayment, in consideration for any services of a managerial, technical or consultancy nature rendered in the Contracting State of which the payer is a resident. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 royalties or Article 14, as the case may be, shall applyfees for technical services are taxable in that other Contracting State according to its own law. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political or administrative subdivision, or a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to make the payments was incurred, incurred and the payments are borne by that permanent establishment or fixed base, then the royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceedsservices, having regard to the use, right or information for whatever reasonwhich 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 that case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: a) in the case of royalties 10 exceed 7 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent services. The competent authorities of the gross amount Contracting States shall by mutual agreement settle the mode of such feesapplication of this limitation. (2) 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 cinematographic films cinematograph films, and films or tapes for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information (know-how) concerning industrial, commercial or scientific experience. (3) 4. The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature rendered in the Contracting State of which the payer is a residentnature. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, a case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services, having regard to the use, right, information or services paid exceedsfor which they are paid, for whatever reason, 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services the tax so charged shall not exceed: a) in the case of royalties 10 per cent of the gross amount of such royalties, b) in the case of fees for technical services 7.5 per cent of the gross amount of such fees. (2) 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 cinematographic films and films or tapes for radio or television broadcasting), any patent, trade xxxxmark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerial, technical or consultancy nature rendered in the Contracting State of which the payer is a resident. (4) The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to make the payments was incurred, and the payments are borne by that permanent establishment or fixed base, then the royalties or fees for technical services shall be deemed to arise in the Contracting 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 other person, the amount of the royalties or fees for technical services paid exceeds, for whatever reason, 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services services, the tax so charged shall not exceed: a) in the case of royalties 10 exceed 15 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) 3. The term "royalties" 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 cinematographic films and cinematograph film, or films or tapes used for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "" fees for technical servicesservices " as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the paymentspayments and to any individual for independent personal services mentioned in Article 15, in consideration for any services of a managerial, technical or consultancy nature rendered in consultative nature, including the Contracting State provison of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph paragraphs 1 and 2 of this Article shall not apply if the beneficial benecficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise through a permanent establishment situated therein, there or performs perform in that other State independent personal services from a fixed base situated therein, and the right, property or contract in respect of which the royalties or fees for technical services are and paid is effectively connected with such permanent establishment or fixed base. In such case, cases the provisions of Article 7 or Article 1415, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, not has in a Contracting contracting State a permanent establishment or a fixed base in connection with which the obligation to make the payments was incurred, incurred and the payments are borne by that the permanent establishment or fixed base, then the royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment estiblishment or fixed base is situated. (6) 7. Where, by reason of owing to a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties or fees for technical services paid exceedspaid, having regard to the use, right or information for whatever reasonwhich they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such casecases, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, State due regard being had to the other provisions of this AgreementConvention.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and or fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: a) in the case of royalties exceed 10 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent services. The competent authorities of the gross amount Contracting States shall by mutual agreement settle the mode of such feesapplication of this limitation. (2) 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 (work, including cinematographic cinematograph films and films films, tapes or tapes discs used for radio or television broadcasting), any patent, trade xxxxmark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "“fees for technical services" ” as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in received as a consideration for any services of a managerial, technical or consultancy nature rendered nature, but does not include payments for services mentioned in the Contracting State of which the payer is a residentArticle 15. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) 6. Royalties and or fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he that person is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to make right, property or contract in respect of which the payments was incurredroyalties or fees for technical services are paid is effectively connected, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services, having regard to the use, right or information, or services paid exceedsfor which they are paid, for whatever reason, 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 Contracting State, due regard being had to the other provisions of this AgreementConvention.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and or fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State 2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: a) in the case of royalties exceed 10 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2a) 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 (work, including cinematographic films and films cinematograph films, or tapes used for television or radio or television broadcasting), any patent, trade xxxxmark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3b) The term "fees for technical services" as used in this Article means payments of any kind to any personkind, other than payments to an employee those mentioned in Articles 14 and 15 of the person making the payments, in this Agreement as consideration for any services of a managerial, managerial or technical or consultancy nature rendered in the Contracting State of which the payer is a residentservices or technical assistance. (4) . The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, services being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5a) Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a territorial or local authority authority, or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6b) WhereWhere under sub-paragraph (a) royalties or fees for technical services do not arise in one of the Contracting States, by reason of a special relationship between the payer and the beneficial owner royalties relate to the use of, or between both of them and some other personthe right to use, the amount right or property, or the fees for technical services relate to services performed, in one of the Contracting States, the royalties or fees for technical services paid exceeds, for whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner shall be deemed to arise 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 that Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the and fees for technical services services, the tax so charged shall not exceed: a) in the case of royalties 10 exceed 15 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) 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 cinematographic cinematograph films and or films or tapes used for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial commercial, or scientific experienceexperiment. (3) 4. The term "fees for technical services" as used in this Article means payments of any kind amount to any person, person other than payments to an employee of the person making the payments, in consideration for any the services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provisions of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, services being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) 6. Royalties and or fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation right or property or contract giving rise to make the payments was incurredroyalties or fees for technical services is effectively connected, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, base then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceedspaid, having regard to the use, right, information or technical services for whatever reasonwhich 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and or fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services services, the tax so charged shall not exceed: a) in the case of royalties exceed 10 per cent cent. of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) 3. The term "royalties" as used in this Article 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 cinematographic cinematograph films and films films, tapes or tapes discs for radio or television broadcasting), any patent, trade xxxxmark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "fees for technical services" as used in this Article article means payments of any kind to any person, other than payments to an employee of the person making the payments, in received as a consideration for any services of a managerial, technical or consultancy nature rendered nature, including the provision of services by technical or other personnel, but does not include payments for services mentioned in the Contracting State of which the payer is a residentarticle 15. (4) 5. The provisions of paragraph 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article article 7 or Article 14, article 14 as the case may be, shall apply. (5) 6. Royalties and or fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to make right, property or contract in respect of which the payments was incurredroyalties or fees for technical services are paid is effectively connected, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceeds, for whatever reason, 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 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties royalties, or of the fees for technical services services, the tax so charged shall not exceed: aexceed 22.5 (twenty-two and a half) in the case of royalties 10 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) 3. The term "'royalties" ' as used in this Article 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 (work, including cinematographic films and cinematograph films or tapes used for radio or television broadcasting), any patent, trade xxxxmark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "'fees for technical services" ' as used in this Article article means payments of any kind amount to any person, person other than payments to an employee of the a person making the payments, in consideration for any the services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for or technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article article 7 or Article 14article 15, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceeds, for whatever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner paid in the absence of such relationship, the provisions of this Article 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and or fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: aexceed 10% (ten per cent) in the case of royalties 10 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2a) 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 cinematographic films and cinematograph films, or films or tapes used for radio or television broadcasting), any patent, trade xxxxmark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3b) The term "“fees for technical services" ” as used in this Article means payments of any kind to any personkind, other than payments to an employee those mentioned in Articles 14 and 15 of the person making the payments, in this Agreement as consideration for any services of a managerial, managerial or technical or consultancy nature rendered in services, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) . The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5a) Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority authority, or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6b) WhereWhere under sub-paragraph (a) royalties or fees for technical services do not arise in one of the Contracting States, by reason of a special relationship between the payer and the beneficial owner royalties relate to the use of, or between both of them and some other personthe right to use, the amount right or property, or the fees for technical services relate to services performed, in one of the Contracting States, the royalties or fees for technical services paid exceeds, for whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner shall be deemed to arise 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 that Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws law of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services the tax so charged shall not exceedexceed : a(i) in the case of royalties relating to the payments for the use of, or the right to use, industrial, commercial or scientific equipment, 10 per cent of the gross amount of such the royalties,; b(ii) in the case of fees for technical services 7.5 and other royalties, 20 per cent of the gross amount of such feesfees for technical services or royalties. (2) 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 (work, including cinematographic films and or films or tapes used for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "fees for technical services" as used in this Article means payments of any kind to any person, person other than payments to an employee of the person making the paymentspayments and to any individual for independent personal services mentioned in Article 15 (Independent Personal Services), in consideration for any the services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 1415, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is in that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, services whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting 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 other person, the amount of the royalties or fees for technical services paid exceeds, for whatever reason, 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: a) in the case of royalties 10 exceed 15 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) 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 cinematographic films and cinematograph films or films, or tapes used for radio or television broadcasting), any patent, trade xxxxmark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "fees for technical services" as used in this Article means payments any consideration for the provision or rendering of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerial, technical or consultancy nature rendered services by a resident of a Contracting State in the other Contracting State but does not include consideration for any activities mentioned in the paragraph 3 of which the payer is a residentArticle 5, and in Article 14 or Article 15. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties was incurred, and the payments such royalties are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceedsservices, having regard to the use, right or information for whatever reasonwhich they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationshipsuch, 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the and fees for technical services services, the tax so charged shall not exceed: a) in the case of royalties 10 exceed 15 per cent cent. of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) 3. The term "royalties" as used in this Article 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 cinematographic cinematograph films and or films or tapes used for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial commercial, or scientific experienceexperiment. (3) 4. The term "fees for technical services" as used in this Article article means payments of any kind amount to any person, person other than payments to an employee of the person making the payments, in consideration for any the services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, services being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) 6. Royalties and or fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation right or property or contract giving rise to make the payments was incurredroyalties or fees for technical services is effectively connected, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, base then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceedspaid, having regard to the use, right, information or technical services for whatever reasonwhich 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 article shall apply only to the last-last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) Royalties and fees for technical services arising in a Contracting State and paid to a resident resi­ dent of the other Contracting State may be taxed in that other State. (2) However, such royalties and fees for technical services may also be taxed in the Contracting Con­ tracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: a) in the case of royalties 10 exceed 7 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent services. The competent authorities of the gross amount Contracting States shall by mu­ tual agreement settle the mode of such feesapplication of this limitation. (23) 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 cinematographic films cinematograph films, and films or tapes for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information (know­ how) concerning industrial, commercial or scientific experience. (34) The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature rendered in the Contracting State of which the payer is a residentnature. (45) The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties royal­ ties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise arise, through a permanent establishment situated therein, or performs in that other State independent independ­ ent personal services from a fixed base situated therein, and the right, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively connected con­ nected with such permanent establishment or fixed base. In such case, a case the provisions of Article Ar­ ticle 7 or Article 14, as the case may be, shall apply. (56) Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation ob­ ligation to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (67) 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 or fees for technical services, having regard to the use, right, information or services paid exceedsfor which they are paid, for whatever reason, ex­ ceeds 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-last­ mentioned amount. In such case, the excess part of the payments shall remain taxable according accord­ ing to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties royalties, or of the fees for technical services services, the tax so charged shall not exceed: a) in the case of royalties 10 exceed 30 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) 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 (work, including cinematographic cinematograph films and or films or tapes used for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use ofuse, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experienceequipment. (3) 4. The term "fees for technical servicesServices" as used in this Article article means payments of any kind amount to any person, person other than payments to an employee of the a person making the payments, in consideration for any the services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of or the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceeds, for whatever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner paid 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services the tax so charged shall not exceed: a) in the case of royalties 10 exceed 1 [10] per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent services. The competent authorities of the gross amount Contracting States shall by mutual agreement settle the mode of such feesapplication of this limitation. (2) 3. The term "royalties" as used in this Article 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 cinematographic cinematograph films, films and films or video tapes for use in connection with television or tapes for use in connection with radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "fees for technical services" as used in this Article article means payments of any kind to any person, other than payments to an employee of the person persons making the paymentspayments and to any individual for independent personal services mentioned in Article 14, in consideration for any services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph 1 of this Article paragraphs (1) and (2 ) shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise services, 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, right of property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article article 7 or Article article 14, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceedsservices, having regard to the use, right or information for whatever reasonwhich 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 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 Contracting State, due regard being had to the other provisions of this AgreementConvention. 1. Substituted for "30" by Notification No. GSR 37(E), dated 12-1-2000.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and or fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed: a) in the case of royalties exceed 10 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2a) 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 cinematographic cinematograph films and or films or tapes used for television or radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3b) The term "fees for technical services" as used in this Article means payments of any kind to any personkind, other than payments to an employee those mentioned in Articles 14 and 15 of the person making the payments, in this Agreement as consideration for any services of a managerial, managerial or technical or consultancy nature rendered in services, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) . The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, services being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority authority, or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting 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 other person, the amount of the royalties or fees for technical services paid exceedsservices, having regard to the use, right or information for whatever reasonwhich 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and or fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: aexceed 10% (ten per cent) in the case of royalties 10 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2a) 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 cinematographic films and cinematograph films, or films or tapes used for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3b) The term "fees for technical services" as used in this Article means payments of any kind to any personkind, other than payments to an employee those mentioned in Articles 14 and 15 of the person making the payments, in this Agreement as consideration for any services of a managerial, managerial or technical or consultancy nature rendered in services, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) . The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5a) Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority authority, or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6b) WhereWhere under sub-paragraph (a) royalties or fees for technical services do not arise in one of the Contracting States, by reason of a special relationship between the payer and the beneficial owner royalties relate to the use of, or between both of them and some other personthe right to use, the amount right or property, or the fees for technical services relate to services performed, in one of the Contracting States, the royalties or fees for technical services paid exceeds, for whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner shall be deemed to arise 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 that Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and or fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services services, the tax so charged shall not exceed: a) in the case of royalties exceed 10 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) 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 cinematographic cinematograph films and films films, tapes or tapes discs for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in received as a consideration for any services of a managerial, technical or consultancy nature rendered nature, including the provision of services by technical or other personnel, but does not include payments for services mentioned in the Contracting State of which the payer is a residentArticle 15. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) 6. Royalties and or fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to make right, property or contract in respect of which the payments was incurredroyalties or fees for technical services are paid is effectively connected, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceeds, for whatever reason, 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and or fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services is a resident of the other Contracting State the tax so charged shall shal not exceed: a) in the case of royalties exceed 10 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2a) 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 cinematographic cinematograph films and or films or tapes used for television or radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3b) The term "fees for technical services" as used in this Article means payments of any kind to any personkind, other than payments to an employee those mentioned in Articles 14 and 15 of the person making the payments, in this Agreement as consideration for any services of a managerial, managerial or technical or consultancy nature rendered in services, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) . The provisions of paragraph 1 of this Article shall and 2 shal not apply if the beneficial owner of the royalties or fees for technical services, services being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively ef ectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 14, as the case may be, shall shal apply. (5a) Royalties and fees for technical services shall shal be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub­division, a local authority authority, or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall shal be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6b) WhereWhere under sub­paragraph (a) royalties or fees for technical services do not arise in one of the Contracting States, by reason of a special relationship between the payer and the beneficial owner royalties relate to the use of, or between both of them and some other personthe right to use, the amount right or property, or the fees for technical services relate to services performed, in one of the Contracting States, the royalties or fees for technical services paid exceeds, for whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner shal be deemed to arise 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 that Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and or fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State 2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services is a resident of the other Contracting State, the tax so charged shall sha l not exceed: a) in the case of royalties exceed 10 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2a) 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 (work, including cinematographic films and films cinematograph films, or tapes used for television or radio or television broadcasting), any patent, trade xxxxmark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3b) The term "fees for technical services" as used in this Article means payments of any kind to any personkind, other than payments to an employee those mentioned in Articles 14 and 15 of the person making the payments, in this Agreement as consideration for any services of a managerial, managerial or technical or consultancy nature rendered in the Contracting State of which the payer is a residentservices or technical assistance. (4) . The provisions of paragraph paragraphs 1 of this Article shall and 2 sha l not apply if the beneficial owner of the royalties or fees for technical services, services being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively e fectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 14, as the case may be, shall sha l apply. (5a) Royalties and fees for technical services shall sha l be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub­division, a territorial or local authority authority, or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall sha l be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6b) WhereWhere under sub­paragraph (a) royalties or fees for technical services do not arise in one of the Contracting States, by reason of a special relationship between the payer and the beneficial owner royalties relate to the use of, or between both of them and some other personthe right to use, the amount right or property, or the fees for technical services relate to services performed, in one of the Contracting States, the royalties or fees for technical services paid exceeds, for whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner sha l be deemed to arise 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 that Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services services, the tax so charged shall not exceed: a) in the case of royalties 10 exceed 22.5 per cent cent. of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) 3. The term "royalties" royalties " as used in this Article 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 (work, including cinematographic films and cinematograph films or tapes used for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "" fees for technical servicesservices " as used in this Article article means payments of any kind amount to any person, person other than payments to an employee of the a person making the payments, in consideration for any the services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article article 7 or Article 14article 15, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceeds, for whatever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner paid in the absence of such relationship, the provisions of this Article article shall apply only to the last-mentioned amount. In , and in such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties royalties, or of the fees for technical services services, the tax so charged shall not exceedexceed : (a) in the case of royalties 10 15 per cent of the gross amount of such royalties,the royalties relating to copyrights of literary, artistic or scientific works, other than cinematograph films or films or tapes used for radio or television broadcasting; and (b) in the case of fees for technical services 7.5 20 per cent of the gross amount of such feesthe royalties in all other cases or fees for technical services. (2) 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 cinematographic films and films cinematograph films, or films, or tapes used for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "fees for technical services" as used in this Article means payments of any kind amount to any person, person other than payments to an employee of the person making the payments, in consideration for any the services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, a case the provisions of Article 7 or Article 1415, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority thereof, or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting 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 other person, the amount of the royalties or fees for technical services paid exceeds, for whatever reason, 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and or fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services the tax so charged shall not exceed: a) in the case of royalties exceed 10 per cent cent. of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) a. The term "royalties" as used in this Article 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 cinematographic cinematograph films and films or tapes for television or radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, any industrial, commercial, commercial or scientific equipment, equipment or for information concerning industrial, commercial or scientific experience.; (3) The b. the term "fees for technical services" as used in this Article means payments payment of any kind to any person, other than payments to an employee of the person making the payments, in consideration for the rendering of any services of a managerial, technical or consultancy nature rendered services including the provision of services by technical or other personnel but does not include payments for services mentioned in the Contracting State articles 14 and 15 of which the payer is a residentthis Agreement. (4) . The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, services being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article article 7 or Article article 14, as the case may be, shall apply. (5) . Royalties and or fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments was incurred, and the payments royalties or fees for technical services are borne by that such permanent establishment establishment, or fixed base, base then the such royalties or fees for technical services shall be deemed to arise in the Contracting 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 other person, the amount of the royalties or fees for technical services paid exceedshaving regard to the use, right or information for whatever reasonwhich 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 article shall apply only to the last-last mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in the that other State. 2. However, such royalties and fees for technical services may also be taxed in that Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services services, the tax so charged shall not exceed: a) in the case of royalties 10 exceed 15 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) 3. The term "royalties" as used in this Article 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 cinematographic films and cinematograph films, or films or tapes used for radio or television broadcasting), any patent, trade xxxxtrademark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "fees for technical services" as used in this Article article means payments of any kind to any person, other than payments to an employee of the person making the paymentspayments and to any individual for independent personal services mentioned in article 15, in consideration for any services of a managerial, technical or consultancy nature rendered in consultative nature, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph 1 paragraphs (1) and (2) of this Article article shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise through a permanent establishment situated therein, or performs perform in that other State independent personal services from a fixed base situated therein, and the right, property or contract in respect of which the royalties or fees for technical services are and paid is effectively connected with such permanent establishment or fixed base. In such case, cases the provisions of Article article 7 or Article 14article 15, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, not has in a Contracting State a permanent establishment or of a fixed base in connection with which the obligation to make the payments was incurred, incurred and the payments are borne by that the permanent establishment or fixed base, then the royalties or fees for technical services shall be deemed to arise in the Contracting 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 other person, the amount of the royalties or fees for technical services paid exceeds, for whatever reason, 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws law of that State, but if ; provided that where the recipient royalties or fees for technical services are paid to a resident of the other Contracting State who is the beneficial owner thereof and they are paid in respect of a right or property which is first granted, or under a contract which is signed, after the royalties or date of the fees for technical services entering into force of this Convention, the tax so charged shall not exceed:exceed,---- a) a. in the case of royalties 10 royalties, 40 per cent of the gross amount of such royalties,thereof; b) b. in the case of fees for technical services 7.5 services, 20 per cent of the gross amount of such feesthereof. (2) 3. The term "royalties" as used in this Article means payments of any kind including rentals received as a consideration consideration a. for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematographic films cinematograph films, and films or tapes for television or radio broadcasting b. for the use of, or television broadcasting)the right to use, any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, any industrial commercial or scientific equipment, or ; c. for information concerning industrial, commercial or scientific experience. (3) 4. The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the paymentspayments and to any individual for independent personal services mentioned in Article 14 (Independent Personal Services), in consideration for any services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 (Business Profits) or Article 1414 (Independent Personal Services), as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting contracting State when where the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to make the payments was incurred, incurred and the payments are borne by that permanent establishment or fixed base, then the royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or the fixed base is situated. (6) 7. Where, by reason of owing to a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties or fees for technical services paid exceeds, exceeds for whatever reason, reason the amount which would have been agreed upon by the payer and the beneficial owner paid in the absence of such relationship, the provisions of this Article shall apply only to the last-last mentioned amount. In such that case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties royalties, or of the fees for technical services services, the tax so charged shall not exceed: a) in the case of royalties 10 exceed 15 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) 3. The term "royalties" as used in this Article 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 (work, including cinematographic cinematograph films and or films or tapes used for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "fees for technical services" as used in this Article article means payments of any kind amount to any person, person other than payments to an employee of the a person making the payments, in consideration for any the services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 7, or Article 14, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceeds, for whatever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner paid 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties royalties, or of the fees for technical services services, the tax so charged shall not exceed: a) in the case of royalties 10 exceed 15 per cent cent. of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) 3. The term "royalties" as used in this Article 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 (work, including cinematographic cinematograph films and or films or tapes used for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "fees for technical services" as used in this Article article means payments of any kind amount to any person, person other than payments to an employee of the a person making the payments, in consideration for any the services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 7, or Article 14, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceeds, for whatever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner paid in the absence of such relationship, the provisions of this Article 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and or fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or is a resident of the fees for technical services other Contracting State, the tax so charged shall not exceed: a) in the case of royalties exceed 10 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2a) 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 cinematographic films cinematograph films, and films or tapes for television or radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3b) The term "fees for technical services" as used in this Article means payments of any kind to any personkind, other than payments to an employee those mentioned in Articles 14 and 15 of the person making the payments, in this Agreement as consideration for any services of a managerial, managerial or technical or consultancy nature rendered in services, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) . The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties and or fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority authority, or a resident of that State. Where, however, the right or property for which the royalties are paid is used within a Contracting State or the fees for technical services relate to services performed, within a Contracting State, then such royalties or fees for technical services shall be deemed to arise in the State in which the right or property is used or the services are performed. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting 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 other person, the amount of the royalties royalties, having regard to the use, right or fees information for technical services paid exceedswhich they are paid, for whatever reason, 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws law of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services the tax so charged shall not exceed: a) i. in the case of royalties relating to the payments for the use of, or the right to use, industrial, commercial or scientific equipment, 10 per cent cent. of the gross amount of such the royalties,; b) ii. in the case of fees for technical services 7.5 and other royalties, 20 per cent cent. of the gross amount of such feesfees for technical services or royalties. (2) 3. The term "royalties" 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 (work, including cinematographic films and or films or tapes used for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "" fees for technical servicesservices " as used in this Article means payments of any kind to any person, person other than payments to an employee of the person making the paymentspayments and to any individual for independent personal services mentioned in Article 15 (Independent Personal Services), in consideration for any the services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 1415, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, services whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceedspaid, for whatever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner paid 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 Contracting State, due regard being had to the other provisions of this AgreementConvention.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other state. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, State but if the recipient is the beneficial owner of the royalties royalties, or of the fees for technical services services, the tax so charged shall not exceed: a) in the case of royalties 10 exceed 22.5 per cent cent. of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) 3. The term "royalties" as used in this Article article means payments of any kind received as a consideration for the use of, or the right to use, use any copyright of literary, artistic or scientific work (work, including cinematographic cinematograph films and or films or tapes used for radio or television broadcasting), broadcasting any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "fees for technical services" as used in this Article article means payments of any kind amount to any person, person other than payments to an employee of the a person making the payments, in consideration for any the services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise arise, through a permanent establishment situated therein, or and performs in that other State independent personal services from a fixed base situated therein, and the right, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such casecases, the provisions of Article article 7 or Article 14article 16, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, an administrative territorial unit, a local authority or a resident of that Statestate. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceeds, for whatever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner paid in the absence of such relationship, the provisions of this Article article shall apply only to the last-mentioned amount. In such casecases, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services the tax so charged shall not exceed: a) a. in the case of royalties 10 per cent of the gross amount of such royalties,; b) b. in the case of fees for technical services 7.5 per cent of the gross amount of such fees. (2) 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 cinematographic payments of any kind in respect of motion picture films and films works on film, tape or tapes other means of reproduction for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, process or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "“fees for technical services" ” as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerial, technical or consultancy nature rendered in the Contracting State of which the payer is a resident. (4) 5. The provisions of paragraph 1 of this Article 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) 6. Royalties and or fees for technical services servies shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to make the payments payment was incurred, and the payments such royalties or fees for technical services are borne by that permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceeds, for whatever reason, 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical included services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for included services may also be taxed in the Contracting State in which they arise and according to the laws of that State, ; but if the recipient is the beneficial owner of the royalties or fees for included services is a resident of the fees for technical services other Contracting State, the tax so charged shall not exceedexceed : (a) in the case of royalties referred to in sub-paragraph (a) of paragraph 3 and fees for included services as defined in this Article (other than services described in sub-paragraph (b) of this paragraph) : (i ) during the first five taxable years for which this Agreement has effect, (A ) 15 per cent of the gross amount of the royalties or fees for included services as defined in this Article, where the payer of the royalties or fees is the Government of that Contracting State, a political sub-division or a public sector company; and (B ) 20 per cent of the gross amount of the royalties or fees for included services in all other cases; and (ii ) during the subsequent years, 15 per cent of the gross amount of the royalties or fees for included services; and (b) in the case of royalties referred to in sub-paragraph (b) of paragraph 3 and fees for included services as defined in this Article that are ancillary and subsidiary to the enjoyment of the property for which payment is received under paragraph 3(b) of this Article, 10 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesincluded services. (2) 3. The term "'royalties" ' as used in this Article means payments : (a) payment of any kind received as a consideration for the use of, or the right to use, any copyright of a literary, artistic artistic, or scientific work (including cinematographic films and cinematograph films or tapes work on film tape or other means of reproduction for use in connection with radio or television broadcasting), any patent, trade xxxxtrademark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, including gains derived from the alienation of any such right or property which are contingent on the productivity, use, or disposition thereof; and (b) payments of any kind received as consideration for the use of, or the right to use, any industrial, commercial, or scientific equipment, other than payments derived by an enterprise described in paragraph 1 of Article 8 from activities described in paragraph 3(c) or for information concerning industrial, commercial or scientific experience4 of Article 8. (3) The term "4. For the purposes of this Article, 'fees for technical included services" as used in this Article ' means payments of any kind to any personperson in consideration for the rendering of any technical or consultancy services (including through the provision of services of technical or other personnel) if such services : (a) are ancillary and subsidiary to the application or enjoyment of the right, property or information for which a payment described in paragraph 3 is received; or (b) make available technical knowledge, experience, skill, know-how, or processes or consist of the development and transfer of a technical plan or technical design. 5. Notwithstanding paragraph 4, 'fees for included services' does not include amount paid : (a) for services that are ancillary and subsidiary, as well as inextricably and essentially linked, to the sale of property other than payments a sale described in paragraph 5(a); (b) for services that are ancillary and subsidiary to the rental of ships, aircraft, containers or other equipment used in connection with the operation of ships or aircraft in international traffic; (c) for teaching in or by educational institutions; (d) for services for the personal use of the individual or individuals making the payment; or (e) to an employee of the person making the payments, payments or to any individual or firm of individuals (other than a company) for professional services as defined in consideration for any services of a managerial, technical or consultancy nature rendered in the Contracting State of which the payer is a residentArticle 14. (4) 6. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical included services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or the fees for technical included services arise 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, property or contract in respect of which the royalties or fees for technical included services are paid is effectively connected with such permanent establishment or fixed base. In such case, a case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) 7. Royalties and fees for technical included services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or the fees for technical included services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to make pay the payments royalties or the fees for included services was incurred, and the payments such royalties or fees for included services are borne by that permanent establishment or fixed base, then the such royalties or fees for technical included services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) Where, 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 or fees for technical included services, having regard to the use, right, information or services paid exceedsfor which they are paid, for whatever reason, 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-last mentioned amount. In such that case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and or fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: a) in the case of royalties exceed 10 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2a) 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 cinematographic cinematograph films and or films or tapes used for television or radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3b) The term "fees for technical services" as used in this Article means payments of any kind to any personkind, other than payments to an employee those mentioned in Articles 14 and 15 of the person making the paymentsthis Agreement, in as consideration for any services of a managerial, managerial or technical or consultancy nature rendered in services, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) . The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent perrmanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority authority, or a resident of that State. Where, however, the person paying the royalties or fees for technical services, services whether he is a resident of a Contracting State or not, has in a Contracting State Stale a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting 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 other person, the amount of the royalties or fees for technical services paid exceedsservices, having regard to the use, right or information for whatever reasonwhich 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the and fees for technical services the tax so charged shall not exceed: (a) in the case of royalties 10 per cent 12.5% of the gross amount of such royalties,; (b) in the case of fees for technical services 7.5 per cent 10% of the gross amount of such fees. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. (2) 3. The term "royalties" as used in this Article means payments of any kind received payments, whether periodical or not, and in whatever form or name or nomenclature to the extent to which they are made as a consideration for for: (a) the use of, or the right rights to use, any copyright of literarycopyright, artistic or scientific work (including cinematographic films and films or tapes for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, trade xxxx or for other like property or right; or (b) the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning any industrial, commercial or scientific experience.equipment; or (3c) the supply of scientific, technical, industrial or commercial knowledge or information; or (d) the use of, or the right to use : (i) motion picture films; or (ii) films or video for use in connection with television; or (iii) tapes for use in connection with radio broadcasting; or (e) total or partial forbearance in respect of the use or supply of any property or right referred to in this paragraph 4. The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerial, technical or consultancy nature rendered in the Contracting State of which the payer is a resident. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with with (a) such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply. with (5b) Royalties and fees for technical services shall be deemed business activities referred to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to make the payments was incurred, and the payments are borne by that permanent establishment or fixed base, then the royalties or fees for technical services shall be deemed to arise in the Contracting 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 other person, the amount of the royalties or fees for technical services paid exceeds, for whatever reason, 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 Contracting State, due regard being had to the other provisions of this Agreement.under

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services the tax so charged shall not exceed: a) in the case of royalties 10 exceed 20 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) 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 cinematographic cinematography films and or films or tapes used for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "fees for technical services" as used in this Article means payments of any kind amount to any person, person other than payments to an employee of the person making the payments, in consideration for any the services of a managerial, technical or consultancy nature rendered in the Contracting State of which the payer is a residentother personnel. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 1415, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments was incurred, and the payments royalties or fees for technical services are borne by that permanent such establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State state in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceeds, for whatever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner paid in the absence of such relationship, the provisions of this Article shall apply to only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: a) in the case of royalties 10 exceed 20 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2a) 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 cinematographic films and cinematograph films, or films or tapes used for radio or television broadcasting), any patent, trade xxxxmark, design or model, model plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3b) The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the paymentspayments and to any individual for independent personal services mentioned in Article14, in consideration inconsideration for any services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) . The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which which, or the contract under which, the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make the payments was incurred, incurred and the payments are borne by that such permanent establishment or fixed base, then the royalties or fees for technical services shall be deemed to arise in the Contracting 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 other person, the amount of the royalties or fees for technical services, having regard to the use, right, information or technical services paid exceedsfor which they are paid, for whatever reason, 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-last- mentioned amount. In such case, the excess part of the payments royalties or fees for technical services shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties royalties, or of the fees for technical services services, the tax so charged shall not exceed: a) in the case of royalties 10 exceed 20 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) 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 (work, including cinematographic films and cinematograph film or films or tapes used for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "fees for technical services" as used in this Article means payments of any kind amount to any person, person other than payments to an employee of the person making the payments, in consideration for any the services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provisions of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such a case, the provisions of Article 7 royalties or Article 14, as the case may be, fees for technical services shall applybe taxable in that other Contracting State according to its own law. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionor administrative sub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceeds, for whatever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner paid in the absence of such relationship, the provisions of this Article 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 Contracting State, due regard being had to the other provisions of this AgreementConvention.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However: (a) the royalties referred to in paragraph 1 of this Article may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services the tax so charged shall not exceed: a) in the case of royalties exceed 10 per cent of the gross amount of such the royalties,; (b) in the case of fees for technical services 7.5 per cent referred to in paragraph 1 of this Article arising in a Contracting State and paid to a resident of the gross amount other Contracting State shall be taxable only in that other State if such resident is the beneficial owner of such feesthe fees for technical services. (2a) The term "“royalties" ”, as used in this Article 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 cinematographic films and films motion pictures or tapes films, recordings on tape or other media used for radio or television broadcastingbroadcasting or other means of reproduction or transmission), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3b) The term "“fees for technical services" ” as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the paymentspayments and to any individual for independent personal services mentioned in Article 14 (Independent Personal Services), in consideration for any services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provisions of which the payer is a residentservices of technical or other personnel. (4) . The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties and or fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting 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 other person, the amount of the royalties or fees for technical services paid exceedsservices, having regard to the use, right or information for whatever reasonwhich 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 Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and or fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise and and, according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed: a) in the case of royalties exceed 10 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2a) 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 cinematographic cinematograph films and or films or tapes used for television or radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3b) The term "fees for technical services" as used in this Article means payments of any kind to any personkind, other than payments to an employee those mentioned in Articles 14 and 15 of the person making the payments, in this Agreement as consideration for any services of a managerial, managerial or technical or consultancy nature rendered in services, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) . The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, services being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5a) Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority authority, or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6b) WhereWhere under sub-paragraph (a) royalties or fees for technical services do not arise in one of the Contracting States, by reason of a special relationship between the payer and the beneficial owner royalties relate to the use of, or between both of them and some other personthe right to use, the amount right or property, or the fees for technical services relate to services performed, in one of the Contracting States, the royalties or fees for technical services paid exceeds, for whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner shall be deemed to arise 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 that Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties royalties, or of the fees for technical services services, the tax so charged shall not exceed: a) in the case of royalties 10 exceed 20 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2) 3. The term "royalties" 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 (work, including cinematographic cinematograph films and or films or tapes used for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "" fees for technical servicesservices " as used in this Article means payments of any kind amount to any person, person other than payments to an employee of the person making the payments, in consideration for any the services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provisions of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, a case the provisions of Article 7 royalties or Article 14, as the case may be, fees for technical services shall applybe taxable in that other Contracting State according to its own law. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionor administrative sub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceeds, for whatever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner paid in the absence of such relationship, the provisions of this Article 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 Contracting State, due regard being had to the other provisions of this AgreementConvention.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed: a) in the case of royalties 10 exceed 20 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2a) 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 cinematographic films and cinematograph films, or films or tapes used for radio or television broadcasting), any patent, trade xxxxmark, design or model, model plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3b) The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the paymentspayments and to any individual for independent personal services mentioned in Article 14, in consideration for any services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) . The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, right or property or contract in respect of which which, or the contract under which, the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5) . Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make the payments was incurred, incurred and the payments are borne by that such permanent establishment or fixed base, then the royalties or fees for technical services shall be deemed to arise in the Contracting 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 other person, the amount of the royalties or fees for technical services, having regard to the use, right, information or technical services paid exceedsfor which they are paid, for whatever reason, 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 royalties or fees for technical services shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and or fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed: a) in the case of royalties exceed 10 per cent of the gross amount of such royalties, b) in the case of royalties or fees for technical services 7.5 per cent of the gross amount of such feesservices. (2a) 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 cinematographic films and cinematograph films or tapes films or taps or discs used for television or radio or television broadcasting), any patent, trade xxxxmark, design or model, plan, secret formula or process, or for the use of, or the right to use, us industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3b) The term "fees for technical services" as used in this Article means payments of any kind to any personkind, other than payments to an employee those mentioned in Articles 14 and 15 of the person making the payments, in this Agreement as consideration for any services of a managerial, managerial or technical or consultancy nature rendered in services, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) . The provisions of paragraph 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, services being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated thereinthere in, and the right, right or property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, case the provisions of Article 7 or Article 14, as the case may be, shall apply. (5a) Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority authority, or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or not, not has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne born by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6b) WhereWhere under sub-paragraph (a) royalties or fees for technical services do not arise in one of the Contracting States, by reason of a special relationship between the payer and the beneficial owner royalties relate to the use of or between both of them and some other personthe right to use, the amount right or property, or the fees for technical services relate to services performed, in one of the Contracting States, the royalties or fees for technical services paid exceeds, for whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner shall be deemed to arise 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 that Contracting State, due regard being had to the other provisions of this Agreement.

ROYALTIES AND FEES FOR TECHNICAL SERVICES. (1) . Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws law of that State, but if the recipient is the beneficial owner of the royalties or of the fees for technical services the tax so charged shall not exceedexceed : a(i) in the case of royalties relating to the payments for the use of, or the right to use, industrial, commercial or scientific equipment, 10 per cent of the gross amount of such the royalties,; b(ii) in the case of fees for technical services 7.5 and other royalties, 20 per cent of the gross amount of such feesfees for technical services or royalties. (2) 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 (work, including cinematographic films and or films or tapes used for radio or television broadcasting), any patent, trade xxxx, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. (3) 4. The term "fees for technical services" as used in this Article means payments of any kind to any person, person other than payments to an employee of the person making the paymentspayments and to any individual for independent personal services mentioned in Article 15 (Independent Personal Services), in consideration for any the services of a managerial, technical or consultancy nature rendered in nature, including the Contracting State provision of which the payer is a residentservices of technical or other personnel. (4) 5. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise 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, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 1415, as the case may be, shall apply. (5) 6. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is in that State itself, a political subdivisionsub-division, a local authority or a resident of that State. Where, however, the person paying the royalties or fees for technical services, services whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments royalties or fees for technical services was incurred, and the payments such royalties or fees for technical services are borne by that such permanent establishment or fixed base, then the such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 7. 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 or fees for technical services paid exceedspaid, for whatever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner paid 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 Contracting State, due regard being had to the other provisions of this AgreementConvention.