Common use of Royalties Clause in Contracts

Royalties. 1. Royalties 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 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 the tax so charged shall not exceed 12.5% of the gross amount of the royalties. 3. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base with which the right or property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in derived from a Contracting State and paid to by a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in from which they arise are derived and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% of the gross amount of the royalties. 3. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business has in the other Contracting State in which the royalties arise, through arise a permanent establishment situated therein, therein or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties 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. 4. Royalties shall be deemed to arise be derived in a Contracting State when where the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connected, was incurred and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. 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, person the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such that case, the excess part of the payments payment shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a the right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7▇. In the ▇▇ this Article the term "royalties" 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, any work including cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment equipment, or for information concerning industrial, commercial or scientific experience.

Royalties. (1. ) Royalties 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 may also be taxed in the Contracting State in which they arise and according to in accordance with the laws of that State, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% 10 per cent of the gross amount of the royaltiesroyalties in the meaning of paragraph 4 subparagraph a) of this Article. (3. ) However, such royalties may also be taxed in the Contracting State in which they arise and in accordance with the laws of that State, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 5 per cent of the gross amount of the royalties in the meaning of paragraph 4 subparagraph b) of this Article. (4) The term „royalties“ as used in this Article means payments of any kind received as a consideration for: a) the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films; b) any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. (5) The provisions of paragraphs 1 1, 2 and 2 3 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 4. (6) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a or local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. (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, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. (1. ) Royalties arising in derived from sources within a Contracting State and paid to by a person who is a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties may also be taxed in the that first-mentioned Contracting State in which they arise and according to the laws law of that State, but if the recipient but, where that person is the beneficial owner of the royalties royalties, the amount of tax so charged shall not exceed 12.5% 15 per cent of the gross amount of the royalties. (2) The term “royalties” in this Article means payments of any kind to the extent to which they are made as consideration for— (a) the use of or the right to use any— (i) copyright, patent, design or model, plan, secret formula or process, trade-mark, or other like property or right; (ii) industrial, agricultural, commercial or scientific equipment; (iii) motion picture films; or (iv) films or video tapes for use in connection with television or tapes for use in connection with radio broadcasting; (b) the supply of— (i) scientific, technical, industrial or commercial knowledge or information; (ii) any assistance which is given as a means of enabling the application or enjoyment of such knowledge or information; or (c) the supply by a resident of a Contracting State of management services in the other Contracting State, but does not include natural resource royalties. (3. ) The provisions limitation on the amount of paragraphs 1 and 2 tax for which paragraph (1) of this Article provides shall not apply if the person who is the beneficial owner of the royalties, being a resident of a Contracting State, carries on business has in the other Contracting State in which the royalties arise, through a permanent establishment situated thereinand the knowledge, information, assistance, right or performs property giving rise to the royalties is effectively connected with that permanent establishment. In such a case, the royalties may be taxed in that other Contracting State independent personal services from a fixed base situated therein, and in accordance with the right or property in respect law of which the royalties 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 applythat other Contracting State. (4. Royalties shall be deemed ) Where the application of the limitation on the amount of tax for which paragraph (1) of this Article provides is not excluded by virtue of paragraph (3) of this Article but owing to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base with which the right or property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer person paying the royalties and the person who is the beneficial owner of the royalties, or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, royalties paid exceeds the amount which would might have been expected to have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions limitation on the amount of tax for which paragraph (1) of this Article provides 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 law of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in derived from a resident of a Contracting State and paid to by a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in from which they arise are derived and according to the laws law of that State, but if the recipient is where the beneficial owner of the royalties is subject to tax thereon in the other State, the tax so charged shall not exceed 12.515% of the gross amount of the royalties. 3. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business has in the other Contracting State in of which the company paying the royalties arise, through is a resident a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with the business carried on through 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. 4. Royalties shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connected, was incurred and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the a Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of owing to a special relationship between the payer and the beneficial owner or between both of them and some other personpersons, the amount of the royalties, having regard to the use, right or information for which they are paid, 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-last- mentioned amount. In such that case, the excess part of the payments payment shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a the right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for reasons other than bona fide commercial reasonsconsideration. 7. In the this Article the term "royalties" means payments payment of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, any work including cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, model, plan, secret formula or process, process or for the use of, or the right to use, industrial, commercial or scientific equipment equipment, or for information concerning industrial, commercial or scientific experience.

Royalties. (1. ) Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may shall be taxed taxable only in that other State. (2. However) The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, such royalties may also be taxed in or the Contracting State in which they arise and according right to the laws use, any copyright of that Stateliterary, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% of the gross amount of the royaltiesartistic or scientific work including cinematograph films, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. (3. ) The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. (4. ) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (5. ) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 arising in a Contracting State may also be taxed in the that Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 10 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or any patent, trade mark, design or model, plan, or secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 may also be taxed in the Contracting State in which they arise arise, and according to the laws law of that State, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% 10 per cent of the gross amount of the such royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 arising in a Contracting State may also be taxed in the that Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, or secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may shall be taxed taxable only in that other State. 2. HoweverThe term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, such royalties may also be taxed in or the Contracting State in which they arise right to use, any copyright of literary, artistic or scientific work, including cinematograph films and according recordings for radio and television broadcasting, any patent, know how, computer programmes, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience or for the use of, or the right to the laws of that Stateuse, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% of the gross amount of the royaltiesindustrial, commercial or scientific equipment. 3. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated thereinestablishment, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article Articles 7 or Article 1415, as the case may be, shall apply. 4. Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itselfContracting State, a political subdivision (in case of Nigeria)that State, a local authority, a statutory body authority thereof or a resident of that Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. 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 royaltiesroyalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable taxable, according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 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 is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or discs for radio or television broadcasting), any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties 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. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 with which the right or property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. 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 royaltiesroyalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a 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. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may shall be taxed taxable only in that other State. 2. HoweverThe term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, such royalties may also be taxed in or the Contracting State in which they arise and according right to the laws use, any copyright of that Stateliterary, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% of the gross amount of the royaltiesartistic or scientific work including cinematograph films, computer software, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 3. The provisions of paragraphs paragraph 1 and 2 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, of this Agreement shall apply. 4. Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that Contracting State itself, a political subdivision (in case of Nigeria), or a local authority, a statutory body authority thereof or a resident of that the Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 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 is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other the first-mentioned State. 2. However, such royalties 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 the The tax so charged shall not exceed 12.5% (5) five percent of the gross amount of the royalties. 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 cinematograph films and computer software, any patent, trade ▇▇▇▇, 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 (know-how). 3. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 14and 14 shall apply, as the case may be, shall apply. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 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 the tax so charged shall not exceed 12.5% exceed: (a) 15 per cent of the gross amount of the royaltiesroyalties where the royalties arise or accrue on or before 31st December 1999; (b) 10 per cent of the gross amount of the royalties in any other case. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films, and films or tapes for radio or television broadcasting), any patent, trade ▇▇▇▇, 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 (know-how) concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 of this Article shall likewise apply to sums derived from sources within one of the Contracting States by a resident of the other Contracting State from the alienation of any right or property from which royalties are or may be derived. 5. The provisions of paragraphs 1, 2 and 4 of this Article shall not apply if the beneficial owner of the royaltiesroyalties or of the sums derived, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or the sums arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid or the sums are derived is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 1414 of this Agreement, as the case may be, shall apply. 46. Royalties shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which obligation to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 57. 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 royaltiesroyalties paid exceeds, having regard to the usefor whatever reason, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 68. The provisions of this Article shall not apply if a right it was the main purpose or property giving rise to one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the royalties was created or assigned mainly for the purpose of taking are paid to take advantage of this Article and not for bona fide commercial reasonsby means of that creation or assignment. 79. In the Article event that a resident of a Contracting State is denied relief from taxation in the term "royalties" means payments other Contracting State by reason of any kind received as a consideration for the use ofprovisions of paragraph 8 of this Article, or the right to use, any copyright competent authority of literary, artistic or scientific work, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, model, plan, secret formula or process, or for the use of, or other Contracting State shall notify the right to use, industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experiencecompetent authority of the first-mentioned Contracting State.

Royalties. 1. Royalties 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 arising in a Contracting State may also be taxed in the that Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or any patent, trade ▇▇▇▇, design or model, plan, or secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 may also be taxed in the Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including software, cinematograph films and films or tapes for radio or television broadcasting, any patent, trade ▇▇▇▇, design or model, plan, or secret formula or process, or for information concerning industrial, commercial or scientific experi- ence. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, situat- ed therein and the right or property in respect of which the royalties are paid is effectively effec- tively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article Ar- ticle 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent per- manent establishment or a fixed base in connection with which the right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties ▇▇▇- alties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base estab- lishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having hav- ing regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence ab- sence 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 to the laws of each Contracting State, due regard being had to the other provisions provi- sions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 arising in a Contracting State may also be taxed in the that Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 10 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes used for radio or television broadcasting, or any patent, trade ▇▇▇▇, design or model, plan, or secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 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 is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% exceed: (a) in the case of royalties referred to in subparagraph (a) of paragraph 3 of this Article, 10 per cent of the gross amount of the royalties; (b) in the case of royalties referred to in subparagraph (b) of paragraph 3 of this Article, 10 per cent of the adjusted amount of the royalties. For the purpose of this subparagraph “the adjusted amount” means 70 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article comprises: (a) payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, including cinematograph films, and films, tapes or discs for radio or television broadcasting, or any patent, know-how, trade mark, design or model, plan, secret formula or process; and (b) payments of any kind received as a consideration for the use of, or the right to use, any industrial, commercial or scientific equipment. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. , Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 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, the tax so charged shall not exceed 12.5% 10 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films or films or tapes used for radio or television broadcasting, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, computer system or networking software, or for the use of, or the right to use, industrial, commercial, or scientific equipment or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with a) such permanent establishment or fixed basebase or with b) business activities referred to under c) of paragraph 1 of Article 7. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-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. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may be taxed only in that other State. 2. HoweverNotwithstanding the provisions of paragraph 1, such royalties may also be taxed in the Contracting State in which they arise if they constitute consideration for the use of, or the right to use a) a trademark and according any information concerning industrial, commercial or scientific experience provided in connection with a rental or franchise agreement that includes rights to the laws use a trademark, or b) a motion picture film or work on film or videotape or other means of that Statereproduction for use in connection with television, but if the recipient is the beneficial owner of the royalties however the tax so charged shall not exceed 12.5% 5 percent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic, scientific or other work (including computer software, and cinematographic films), any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 1, 2 and 2 3 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, (Business Profits) shall apply. 45. For the purposes of this Article, a) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which obligation to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment is situated and not in any other State of which the payer is a resident; b) Where subparagraph a) does not operate to treat royalties as arising in either Contracting State, and the royalties are for the use of, or fixed base is situatedthe right to use, in one of the Contracting States, any property or right described in paragraph 3, the royalties shall be deemed to arise in that State. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer 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. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 arising in a Contracting State may also be taxed in the that Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or any patent, trade ▇▇▇▇, design or model, plan, or secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties arising in a Contracting State may also be taxed in the Contracting that State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including software and cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information (know-how) concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, therein or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties 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. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base with which the right or property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. 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 royaltiesroyalties paid exceeds, having regard to the usefor whatever reason, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of No relief shall be available under this Article shall not apply if a right it was the main purpose or property giving rise to one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the royalties was created or assigned mainly for the purpose of taking are paid to take advantage of this Article and not for bona fide commercial reasonsby means of that creation or assignment. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 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 is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 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 cinematography films, any patent, software, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. 1 - Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. 2 - However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% (8) per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3. 3 - The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, 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. 4 - The provisions of paragraphs 1 (1) and 2 (2) shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 4. 5 - Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which obligation to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. 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, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 arising in a Contracting State may also be taxed in the that Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or any patent, trade mark, design or model, plan, or secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in (a) Lessee shall pay to Lessor a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalty or royalties 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 the tax so charged shall not exceed 12.5% out of the gross amount proceeds received by Lessee from the sale or use of Resources, or the re-injection of geothermal resource produced from adjoining property ("Other Resources") in proportion to Lessor's Participation Interest in the operative Unit (as such terms are defined in Section 12, below) from which the Resources are produced, in whole or in part, or from which Other Resources are re-injected through ▇▇▇▇▇ located on the Property. Separate compensation for easements shall also be required at market terms and rates. (b) If Lessee sells any Resources, which do not require processing as described in Section 1(a) of this Agreement produced from the Property as such, a royalty of ten percent (10%) of the royalties. 3. The provisions gross value received from the sale by Lessee of paragraphs 1 and 2 shall not apply them Resources, if sold off the beneficial owner of Property or the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14Unit area, as the case may be, shall applybe paid to Lessor. 4. Royalties shall be deemed (c) If Lessee generates electric power from a generating or power processing facility which utilizes any Resources or otherwise converts any Resources into electric power from a designated resource area or Unit and sells any of the electric power to arise in a Contracting State when the payer is that State itself, a political subdivision one or more third parties (in case of Nigeria"Electricity Revenues"), a local authorityroyalty of three and one-half percent (3.5%) of the gross revenues received from the sale of such electric power. (d) If Lessee uses Resources at a commercial facility other than an electric power generating facility, a statutory body royalty of five percent (5%) of the gross proceeds shall be paid on a proportionate basis to the Lessor. (e) Lessee may use, free of royalty, Resources and electric power developed from the Property for all operations authorized under the Agreement, including operation of the generating facility or facilities, and Lessee shall not be required to account to Lessor for or pay royalty on any Resources reasonably lost or consumed in operations hereunder, provided that, if Lessee is able to purchase power from a resident third-party at lower rates, it shall endeavor to do so. (f) Lessee shall pay to Lessor within thirty (30) days of that Statereceipt of payment from the purchaser of electricity or Resources, or both, the royalties accrued and payable for the preceding calendar month. WhereConcurrently with making each such royalty payment, Lessee shall deliver to Lessor a statement including the supporting statement from the purchaser of the electrical power setting forth the basis for the determination of the royalty then paid by Lessee. (g) In the event Lessee sells any Resources to an entity affiliated with the Lessee, the royalty payment shall be calculated on the greater of: (1) the gross proceeds received by the Lessee or (2) the net fair market value of the Resources sold to the affiliated entity. (h) For purposes of calculating royalties, gross proceeds received from Lessee shall include all revenues directly derived from the sale of electricity from the ownership of power plants receiving Resources from the Property, including all sales of electricity through bilateral power sales contracts; provided, however, the person paying the for purposes of calculating royalties, gross proceeds shall not include any favorable loans, subsidies or tax credits received by the Lessee from power purchase or any governmental entity associated with "green" or "clean" power alternatives, whether he is a resident of a Contracting State such net purchase credits, loans, subsidies or not, has in a Contracting State a permanent establishment tax credits are available now or a fixed base with which the right or property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situatedfuture. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. ‌ (1. ) Royalties 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 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 the tax so charged shall not exceed 12.5% exceed: (a) 15 per cent. of the gross amount of the royaltiesroyalties where the royalties arise or accrue on or before 31st December 1999; (b) 10 per cent. of the gross amount of the royalties in any other case. (3. ) The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films, and films or tapes for radio or television broadcasting), any patent, trade ▇▇▇▇, 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 (know-how) concerning industrial, commercial or scientific experience. (4) The provisions of paragraphs 1 (1) and 2 (2) of this Article shall likewise apply to sums derived from sources within one of the Contracting States by a resident of the other Contracting State from the alienation of any right or property from which royalties are or may be derived. (5) The provisions of paragraphs (1), (2) and (4) of this Article shall not apply if the beneficial owner of the royaltiesroyalties or of the sums derived, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or the sums arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid or the sums are derived is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 1414 of this Agreement, as the case may be, shall apply. 4. (6) Royalties shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which obligation to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. (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 royaltiesroyalties paid exceeds, having regard to the usefor whatever reason, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. (8) The provisions of this Article shall not apply if a right it was the main purpose or property giving rise to one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the royalties was created or assigned mainly for the purpose of taking are paid to take advantage of this Article and not for bona fide commercial reasonsby means of that creation or assignment. 7. (9) In the Article event that a resident of a Contracting State is denied relief from taxation in the term "royalties" means payments other Contracting State by reason of any kind received as a consideration for the use ofprovisions of paragraph (8) of this Article, or the right to use, any copyright competent authority of literary, artistic or scientific work, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, model, plan, secret formula or process, or for the use of, or other Contracting State shall notify the right to use, industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experiencecompetent authority of the first-mentioned Contracting State.

Royalties. 1. Royalties arising in a one of the Contracting State and paid States, being royalties to which a resident of the other Contracting State is beneficially entitled, may be taxed in that other State. 2. However, such Such royalties 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 the tax so charged shall not exceed 12.5% 15 percent of the gross amount of the royalties. 3. Notwithstanding the provisions of paragraph 2, approved industrial royalties derived from Malaysia by a resident of Australia who is the beneficial owner thereof shall be exempt from Malaysian tax. 4. The provisions of paragraphs 1 1, 2 and 2 3 shall not apply if the beneficial owner of person beneficially entitled to the royalties, being a resident of a one of the Contracting StateStates, carries on business has in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid derived a permanent establishment with which the right, property, knowledge, information or assistance giving rise to the royalties is effectively connected with such permanent establishment or fixed baseconnected. In such a case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that Contracting State itself, itself or a political subdivision (in case of Nigeria)subdivision, a local authority, a authority or statutory body thereof or a resident of that StateState for the purposes of its tax. Where, however, the person paying the royalties, whether he is a resident of a one of the Contracting State States or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between Where the payer is related to the person beneficially entitled to the royalties and the beneficial owner or between both of them and some other person, the amount of the royaltiesroyalties paid or credited, having regard to the use, to the right to use, or to the knowledge, information or assistance, for which they are paidpaid or credited, exceeds the amount which would might be expected to have been agreed upon by the payer and the beneficial owner in the absence of such relationshipperson so entitled if they had not been related, the provisions of this Article shall apply only to the last-mentioned amount. In such that case, the excess part of the payments royalties paid or credited shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions For the purposes of this Article shall not apply paragraph, a person is related to another person if a right either person participates directly or property giving rise to indirectly in the royalties was created management, control or assigned mainly for capital of the purpose other, or if any third person or persons participate directly or indirectly in the management, control or capital of taking advantage of this Article and not for bona fide commercial reasonsboth. 7. In the Article the The term "royalties" in this Article means payments or credits of any kind received to the extent to which they are made as a consideration for for: (a) the use of, or the right to use, any copyright of literaryany- (i) copyright, artistic or scientific work, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, design or model, plan, secret formula or process, trade ▇▇▇▇ or for the use of, other like property or the right to use, right; (ii) industrial, commercial or scientific equipment; or (iii) motion picture film or tape for radio or television broadcasting; (b) the supply of scientific, technical, industrial or commercial knowledge or information; (c) the supply of any assistance that is ancillary and subsidiary to, and is furnished as a means of enabling the application or enjoyment of, any such right or property as is described in paragraph (a) (i), any such equipment as is described in paragraph (a) (ii), or any such knowledge or information as is described in paragraph (b); or (d) total or partial forbearance in respect of the use of a property or right referred to in this paragraph. 8. The term "approved industrial royalties" in this Article means royalties as defined in paragraph 7 which are approved and certified by the competent authority of Malaysia as payable for information concerning industrialthe purpose of promoting industrial development in Malaysia and which are payable by an enterprise which is wholly or mainly engaged in activities falling within one of the following classes: (a) manufacturing, commercial assembling or scientific experienceprocessing; (b) construction, civil engineering or ship-building, or (c) electricity, hydraulic power, gas or water supply. 9. Royalties derived by a resident of Australia, being royalties that, as film rentals, are subject to the cinematograph film-hire duty in Malaysia, shall not be liable to Malaysian tax.

Royalties. 1. Royalties 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 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 is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 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 cinematography films, any patent, software, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 may also be taxed in the Contracting State in which they arise and according to the laws of that StateContracting State , but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% exceed: (a) 25 per cent of the gross amount of the royaltiesroyalties arising from the use or the right to use trade marks; (b) 15 per cent of the gross amount of the royalties in all other cases. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes for radio or television broadcasting, any patent, know-how, trade mark, 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. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or of fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is the Government of that State itselfContracting State, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority thereof or a resident of that Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or of fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments payment shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 arising in a Contracting State may also be taxed in the that Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or any patent, trade mark, design or model, plan, or secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State Party and paid to a resident of the other Contracting State Party may be taxed in that other StateContracting Party. 2. However, such royalties may also be taxed in the Contracting State Party in which they arise and according to the laws of that StateContracting Party, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes for radio or television broadcasting, any patent, trade mark, design or model, plan, or secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting StateParty, carries on business in the other Contracting State Party in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State Party when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that StateContracting Party. Where, however, the person paying the royalties, whether he is a resident of a Contracting State Party or not, has in a Contracting State Party a permanent establishment or a fixed base in connection with which the right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State Party in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each StateContracting Party, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 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 is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment or road vehicles and trucks, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body authority thereof or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising (a) Subject to the remainder of this Section 8.06 (Royalties), Licensee shall pay Agios the following royalties on aggregate Net Sales of all Licensed Products, at an incremental royalty rate determined by aggregate annual Net Sales of all Licensed Products in each calendar year during the Term in the Territory: By way of example and not limitation, if Net Sales of all Licensed Products in a Contracting State calendar year are [**] Dollars ($[**]), then the royalty shall be [**]. (b) Running royalties paid by Licensee under this Section 8.06 (Royalties) shall be paid on a Licensed Product-by-Licensed Product and paid Jurisdiction-by-Jurisdiction basis until the latest of (i) the expiration of the last-to-expire Valid Claim in the Agios Patent Rights or Joint Combination Therapy Patent Rights that Covers such Licensed Product in the Field in such Jurisdiction, (ii) expiration of marketing or regulatory exclusivity with respect to such Licensed Product in such Jurisdiction, or (iii) ten (10) years from the First Commercial Sale of such Licensed Product in the Field in such Jurisdiction (each, a “Royalty Term”). Following the expiration of the Royalty Term with respect to a resident particular Licensed Product in the Field in a Jurisdiction (but not following an earlier termination of this Agreement), the other Contracting State may licenses granted by Agios to Licensee pursuant to Section 2.01(a) with respect to such Licensed Product in the Field in such Jurisdiction shall be taxed perpetual, irrevocable, fully-paid and royalty-free, and Net Sales of such Licensed Product shall no longer be included in that other Statethe aggregate Net Sales calculation in Section 8.06(a) but shall be included in calculations of Net Sales for the purposes of Section 8.05 (Sales Milestones Payments). 2. However, such royalties 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 the tax so charged shall not exceed 12.5% of the gross amount of the royalties. 3. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case (c) Notwithstanding the provisions of Article 7 Section 8.06(a), on a Jurisdiction-by-Jurisdiction basis, during any period in such Jurisdiction in which (i) the sale of a given Licensed Product would not infringe a Valid Claim of the Agios Patent Rights or Article 14a Valid Claim of the Joint Combination Therapy Patent Rights and (ii) there is no marketing or regulatory exclusivity with respect to such Licensed Product in such Jurisdiction, Licensee shall pay royalty rates for sales of such Licensed Product in such Jurisdiction that shall be set at [**] percent ([**]%) of the applicable royalty rate determined in accordance with Section 8.06(a). (d) In the event that Licensee or Agios obtains, after the Effective Date, a license under, or other rights to, Patent Rights or Know-How from any Third Party(ies) that are necessary in order to Commercialize a given Licensed Product in the Field in a given Jurisdiction, [**] percent ([**]%) of any and all royalty payments actually paid directly, or indirectly in accordance with Section 2.06(a), as applicable, under such Third Party licenses by Licensee or its Affiliates for sales of such Licensed Product in the case may be, Field in such Jurisdiction in a given calendar quarter shall applybe creditable against the royalty payments due to Agios by Licensee for sales of such Licensed Product in such Jurisdiction in such calendar quarter. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base with which the right or property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, e) Notwithstanding the provisions of this Article shall apply only to Section 8.06(a), on a Jurisdiction-by-Jurisdiction basis, during any period in such Jurisdiction in which (i) the last-mentioned amount. In such case, the excess part sale of a given Licensed Product would infringe a Valid Claim of the payments Joint Combination Therapy Patent Rights but not a Valid Claim of the Agios Patent Rights and (ii) there is no marketing or regulatory exclusivity with respect to such Licensed Product in such Jurisdiction, Licensee shall remain taxable according to pay royalty rates for sales of such Licensed Product in such Jurisdiction that shall be set at [**] percent ([**]%) of the laws of each State, due regard being had to applicable royalty rate determined in accordance with Section 8.06(a). (f) Notwithstanding the other provisions of this Agreement. 6. The provisions the above subparts (c), (d) and (e) of this Article Section, in no event shall not apply if the total royalty rate reduction(s) allowable under such subparts with respect to a right given Licensed Product in a given Jurisdiction in a given calendar quarter, alone or property giving rise together, lead to a reduction of more than [**] percent ([**]%) of the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasonsapplicable royalty rate determined in accordance with Section 8.06(a). 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other the first mentioned State. 2. However, such royalties 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 the The tax so charged shall not exceed 12.5% (5) five percent of the gross amount of the royalties. 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 computer software, cinematograph films, or films or tapes or discs used for radio or television broadcasting), any patent, trade mark, 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 provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base with which the right or right, property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amountamount of royalties. 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. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.Agreement.‌

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may shall be taxed taxable only in that other State. 2. HoweverThe term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, such royalties may also be taxed in or the Contracting State in which they arise and according right to the laws use, any copyright of that Stateliterary, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% of the gross amount of the royaltiesartistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 3. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 7, or Article 14, as the case may be, 14 of this Agreement shall apply. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. (1. ) Royalties arising in a Contracting State territory and paid to a resident of the other Contracting State territory may be taxed in that other Stateterritory. (2. ) However, such royalties may also be taxed in the Contracting State territory in which they arise and according accord­ ing to the laws of that Stateterritory, but if the recipient is the beneficial owner of the royalties is a resident of the other territory, the tax so charged shall not exceed 12.5% 10 per cent of the gross amount of the royalties▇▇▇­ alties. (3) The term "royalties" as used in this Article means payments of any kind received as a con­ sideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experi­ ence. Subject to the provisions of Article 16, the term “royalties“ shall also include payments of any kind for the use or the right to use a person’s name, picture or any other similar per­ sonality rights as well as films or tapes of entertainers' or sportspersons' performances used for radio or television broadcasting. (4) The provisions of paragraphs 1 (1) and 2 (2) shall not apply if the beneficial owner of the royalties▇▇▇­ alties, being a resident of a Contracting Stateterritory, carries on business in the other Contracting State territory in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestab­ lishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 4. (5) Royalties shall be deemed to arise in a Contracting State territory when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State▇▇▇▇▇­ tory. Where, however, the person paying the royalties, whether he is a resident of a Contracting State territory or not, has in a Contracting State territory a permanent establishment or a fixed base in connection with which the right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State territory in which the permanent establishment or fixed base establish­ ment is situated. 5. (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, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess ex­ cess part of the payments shall remain taxable according to the laws of each Stateterritory, due regard re­ gard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 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 is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-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. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 arising in a Contracting State may also be taxed in the that Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or any patent, trade mark, design or model, plan, or secret formula or process, for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. (1. ) Royalties 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 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, the tax so charged shall not exceed 12.5% exceed: (a) 5 per cent of the gross amount of royalties that are for the royaltiesuse of industrial, commercial or scientific equipment; (b) 10 per cent of the gross amount of royalties other than those referred to in sub-paragraph (a). (3. ) The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films, and films or tapes for television or radio broadcasting), any patent, trade ▇▇▇▇, 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 (know- how) concerning industrial, commercial or scientific experience. (4) The provisions of paragraphs 1 (1) and 2 (2) of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 1414 of this Convention, as the case may be, shall apply. 4. (5) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. (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 royaltiesroyalties paid exceeds, having regard to the usefor whatever reason, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. (7) The provisions of this Article shall not apply if a right it was the main purpose or property giving rise to one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the royalties was created or assigned mainly for the purpose of taking are paid to take advantage of this Article and not for bona fide commercial reasonsby means of that creation or assignment. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising (A) Lessor shall be paid in a Contracting State and paid to a resident respect of the sale by Company or its licensees of phonorecords embodying the Masters or the License Masters hereunder and in respect of any other Contracting State may be taxed exploitation by Company or its licensees of such Masters or License Masters, the following earned royalties upon the terms hereinafter set forth: (1) For Masters, the amount Lessor is obligated to pay to any royalty participant for exploitation of the Masters in that other Statethe Territory and the Nonexclusive Territory. (2. However) For License Masters, such royalties may also be taxed the amount Lessor is obligated to pay to the licensor of the License Masters for exploitation of the License Masters in the Contracting State in which they arise Territory and according to the laws of that State, but if the recipient is the beneficial owner Nonexclusive Territory. (B) In respect of the royalties provided for herein: (1) Based upon the tax so charged terms of agreements with third-parties setting forth the obligations of Lessor to such third parties with respect to the Masters and the License Masters, Company shall not exceed 12.5% compute royalties payable to Lessor hereunder within sixty (60) days after the end of each calendar quarter of each year during which phonorecords made hereunder are sold or Company receives proceeds derived from the exploitation of the gross amount Masters or the License Masters, for the preceding three (3) month period, and will render full and complete accountings therefor certified by Company to be accurate and pay such royalties within such sixty (60) days without diminution for any income, excise, or other taxes, tariffs, or duties. Upon the request of Company, Lessor shall provide Company with a copy of each agreement setting forth the royalty obligation of Lessor with respect to each Master or License Master. Payments shall be made in United States dollars by wire transfer. Each such payment shall be made payable to Lessor at such address or bank in the United States as shall be designated in writing from time to time by Lessor. All expenses of currency conversion and transmission shall be borne by Company, and no deduction shall be made from remittances on account of such expenses. Company and Lessor from time to time shall prepare all applications, reports, and other documents that may be required by the respective governments of the royaltiescountries in the Territory and the Nonexclusive Territory in order that remittances may be made in accordance with this Agreement. Failure to submit timely reports and/or payments will incur an additional charge of two percent (2%) per month on any balance unpaid as of the 30th day of the applicable month. Earned royalties shall accrue when phonorecords are billed out or shipped, whichever date is earlier. Company agrees to account for the activities of its subsidiaries, affiliates, sublicensees, and controlled companies as if such subsidiaries, affiliates, sublicensees, and controlled companies were unincorporated divisions within the organization of Company, with their acts those of Company. 3. The provisions (2) Statements rendered by Company shall contain the number of paragraphs 1 and 2 shall not apply if phonorecords sold identified by title of Master or License Master, the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State country in which sold or shipped, the royalties ariseapplicable royalty rate as provided by Lessor under Section VII(A), through a permanent establishment situated thereinthe price upon which the royalty has been computed, or performs in that other Contracting State independent personal services from a fixed base situated thereinall returns, and the right or property basis upon which all return credits have been calculated. Company agrees to retain records concerning the production, sale, and sublicensing of phonorecords, the Masters, and the License Masters for a period in respect no event less than five (5) years following rendition of which the royalties 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 applyany report. 4(3) Lessor and its representatives shall have the right at all reasonable times during regular business hours and upon reasonable notice to inspect and make copies of the books and records of Company, at the place where such records are customarily maintained, insofar as they relate to the production, sale, sublicensing, or other exploitation of the Masters and the License Masters. Royalties Company agrees to cooperate fully with Lessor in making the inspection and copying. If as a result of an inspection it is determined that there are unreported royalties payable to Lessor, Company shall be deemed to arise in a Contracting State when promptly pay Lessor the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the unreported royalties, whether he is a resident plus interest on the payments at the rate of a Contracting State two percent (2%) per month from the date such payment should have been made to Lessor. If the unreported royalties exceed either an aggregate of ten thousand dollars ($10,000.00) or not, has in a Contracting State a permanent establishment more or a fixed base with which the right or property in respect five percent (5%) of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. 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 royaltiestheretofore paid by Company to Lessor, having regard to the use, right or information Company shall reimburse Lessor for which they are paid, exceeds the amount which would have been agreed upon its out-of-pocket costs and professional fees in conducting such examination as well as any attorney fees incurred by the payer and the beneficial owner Lessor in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each State, due regard being had to the other provisions of this Agreementconnection therewith. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 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 cinematograph films, any patent, trade mark, secret formula or process, or for information concerning industrial, commercial or scientific experience. 3. However, such royalties may also be taxed in the Contracting State in which they arise and according to in accordance with the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is the resident of the other Contracting State, the tax so charged shall not exceed 12.5% 10 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 34. Notwithstanding the provisions of paragraph 3 of this Article, in the case of payment of royalties in respect of any copyright of scientific work, any patent, trade mark, secret formula, process or information concerning industrial, commercial or scientific experience the tax charged shall not exceed 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 5. The provisions of paragraphs 1 1, 3 and 2 4 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 1414 of this Convention, as the case may be, shall apply. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base with which the right or property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasonsConvention. 7. In Royalties shall be deemed to arise in a Contracting State when the Article payer is a resident of that State. Where, however, the term "person paying the royalties" means payments , whether he is a resident of any kind received as a consideration for Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the use ofobligation to pay the royalties are paid was incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the right to use, any copyright of literary, artistic State in which the permanent establishment or scientific work, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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 experiencefixed base is situated.

Royalties. 1. Royalties 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 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 is the resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the such royalties. 3. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of the limitation of paragraph 2. 4. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 5. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 46. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated.was 57. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned lastmentioned 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. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may shall be taxed taxable only in that other State. 2. However, such royalties for the use of or the right to use any patent, trademark, design or model, plan, secret formula or process 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 is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitations. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he the payer 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 right or property in respect of which obligation to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a one of the Contracting State and paid States, being royalties to which a resident of the other Contracting State is beneficially entitled, may be taxed in that other State. 2. However, such Such royalties 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 the tax so charged shall not exceed 12.5% 15 percent of the gross amount of the royalties. 3. Notwithstanding the provisions of paragraph 2, approved industrial royalties derived from Malaysia by a resident of Australia who is the beneficial owner thereof shall be exempt from Malaysian tax. 4. The provisions of paragraphs 1 1, 2 and 2 3 shall not apply if the beneficial owner of person beneficially entitled to the royalties, being a resident of a one of the Contracting StateStates, carries on business has in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid derived a permanent establishment with which the right, property, knowledge, information or assistance giving rise to the royalties is effectively connected with such permanent establishment or fixed baseconnected. In such a case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that Contracting State itself, itself or a political subdivision (in case of Nigeria)subdivision, a local authority, a authority or statutory body thereof or a resident of that StateState for the purposes of its tax. Where, however, the person paying the royalties, whether he is a resident of a one of the Contracting State States or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between Where the payer is related to the person beneficially entitled to the royalties and the beneficial owner or between both of them and some other person, the amount of the royaltiesroyalties paid or credited, having regard to the use, to the right to use, or to the knowledge, information or assistance, for which they are paidpaid or credited, exceeds the amount which would might be expected to have been agreed upon by the payer and the beneficial owner in the absence of such relationshipperson so entitled if they had not been related, the provisions of this Article shall apply only to the last-mentioned amount. In such that case, the excess part of the payments royalties paid or credited shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions For the purposes of this Article shall not apply paragraph, a person is related to another person if a right either person participates directly or property giving rise to indirectly in the royalties was created management, control or assigned mainly for capital of the purpose other, or if any third person or persons participate directly or indirectly in the management, control or capital of taking advantage of this Article and not for bona fide commercial reasonsboth. 7. In the Article the The term "royalties" in this Article means payments or credits of any kind received to the extent to which they are made as a consideration for for: (a) the use of, or the right to use, any copyright of literaryany- (i) copyright, artistic or scientific work, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, design or model, plan, secret formula or process, trade mark or for the use of, other like property or the right to use, right; (ii) industrial, commercial or scientific equipment; or (iii) motion picture film or tape for radio or television broadcasting; (b) the supply of scientific, technical, industrial or commercial knowledge or information; (c) the supply of any assistance that is ancillary and subsidiary to, and is furnished as a means of enabling the application or enjoyment of, any such right or property as is described in paragraph (a) (i), any such equipment as is described in paragraph (a) (ii), or any such knowledge or information as is described in paragraph (b); or (d) total or partial forbearance in respect of the use of a property or right referred to in this paragraph. 8. The term "approved industrial royalties" in this Article means royalties as defined in paragraph 7 which are approved and certified by the competent authority of Malaysia as payable for information concerning industrialthe purpose of promoting industrial development in Malaysia and which are payable by an enterprise which is wholly or mainly engaged in activities falling within one of the following classes: (a) manufacturing, commercial assembling or scientific experienceprocessing; (b) construction, civil engineering or ship-building, or (c) electricity, hydraulic power, gas or water supply. 9. Royalties derived by a resident of Australia, being royalties that, as film rentals, are subject to the cinematograph film-hire duty in Malaysia, shall not be liable to Malaysian tax.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties may also be taxed in the Contracting State in which they arise it arises and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 10 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting Con- tracting State may be taxed in that other State. 2. However, such royalties 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 is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 10 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3. The term «royalties» as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films, tapes or discs for radio or tele- vision broadcasting, any patent, trade ▇▇▇▇, 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 experi- ence. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated situ- ated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he that person is a resident of a Contracting State or not, has in a Contracting State a permanent perma- nent establishment or a fixed base in connection with which the right or property in respect of which obligation to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such that permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 may also be taxed in the Contracting State in which they arise where it arises and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is resident of the other Contracting State the tax so charged shall not exceed 12.5% nine (9) percent of the gross amount of the royalties. The Competent Authorities of the Contracting States shall by mutual agreement settle the mode of application of these limitations. 3. The provisions term “royalties” as used in this Article means payments of paragraphs 1 and 2 shall not apply if any kind received as a consideration for the beneficial owner use of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right to use, any copyright of literary, artistic or property scientific work including cinematograph films and works on films , tapes or other means of reproduction for use in respect of which the royalties are paid is effectively connected connection with such permanent establishment television or fixed base. In such case the provisions of Article 7 radio broadcasting, any patent, trade mark, design or Article 14model, as the case may beplan, shall applysecret formula or process, or for information (know-how) concerning industrial, commercial or scientific experience. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner of the royalties or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of No relief shall be available under this Article shall not apply if a right it was the main purpose or property giving rise to one of the main purposes of any person concerned with the creation or assignment of the shares or other rights in respect of which the royalties was created or assigned mainly for the purpose of taking are paid to take advantage of this Article and not for bona fide commercial reasonsby means of that creation or assignment. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may shall be taxed taxable only in that other State. 2. However, State if such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient resident is the beneficial owner of the royalties royalties. 2. The term "royalties" as used in this Article means payments of any kind received as a consideration for the tax so charged shall not exceed 12.5% use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, recordings on tape, other media used for video or television broadcasting or other means of reproduction or transmission, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for the gross amount of use of, or the royaltiesright to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience. 3. The provisions of paragraphs 1 and 2 paragraph (1) of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 8 or Article 1415, as the case may be, shall apply. 4. Royalties shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which obligation to pay the royalties are paid is effectively connected, was incurred and such the royalties are borne by such that permanent establishment or fixed base, then such the royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. 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 royaltiesroyalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of paragraph (1) of this Article shall not apply if a the right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in derived from a resident of a Contracting State and paid to by a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in from which they arise are derived and according to the laws law of that State, but if the recipient is where the beneficial owner of the royalties is subject to tax thereon in the other State, the tax so charged shall not exceed 12.5% 12.5 per cent of the gross amount of the royalties. 3. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business has in the other Contracting State in of which the company paying the royalties arise, through is a resident a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with the business carried on through 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. 4. Royalties shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision (in case of Nigeria)sub- division or an administrative territorial unit, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connected, was incurred and such royalties are borne by such permanent establishment or fixed base, base then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of owning to a special relationship between the payer and the beneficial owner or between both of them and some other personpersons, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such that case, the excess part of the payments payment shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a in the opinion of the competent authorities, the right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7▇. In the ▇▇ this Article the term "royalties" means payments payment 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, any work including cinematograph films and or films or tapes used for radio and or television broadcasting, any patent, trade ▇▇▇▇, design, design or model, plan, secret formula or process, process or for the use of, or the right to use, use industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may shall be taxed taxable only in that other State. 2. HoweverThe term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, such royalties may also be taxed in or the Contracting State in which they arise and according right to the laws of that Stateuse, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% of the gross amount of the royaltiesany copyright or similar right, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience (know-how). 3. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base with which the right or property in respect of connection with which the obligation to pay the royalties are paid is effectively connected, was incurred and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right it was the main purpose or property giving rise to one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the royalties was created or assigned mainly for the purpose of taking are paid to take advantage of this Article and not for bona fide commercial reasonsby means of that creation or assignment. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 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 cinematograph films, any patent, trade ▇▇▇▇, secret formula or process, or for information concerning industrial, commercial or scientific experience. 3. However, such royalties may also be taxed in the Contracting State in which they arise and according to in accordance with the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is the resident of the other Contracting State, the tax so charged shall not exceed 12.5% 10 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 34. Notwithstanding the provisions of paragraph 3 of this Article, in the case of payment of royalties in respect of any copyright of scientific work, any patent, trade ▇▇▇▇, secret formula, process or information concerning industrial, commercial or scientific experience the tax charged shall not exceed 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 5. The provisions of paragraphs 1 1, 3 and 2 4 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 1414 of this Convention, as the case may be, shall apply. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base with which the right or property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasonsConvention. 7. In Royalties shall be deemed to arise in a Contracting State when the Article payer is a resident of that State. Where, however, the term "person paying the royalties" means payments , whether he is a resident of any kind received as a consideration for Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the use ofobligation to pay the royalties are paid was incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the right to use, any copyright of literary, artistic State in which the permanent establishment or scientific work, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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 experiencefixed base is situated.

Royalties. 1. Royalties 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 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 the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, 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. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 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 is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3. The term ―royalties‖ as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or discs for radio or television broadcasting), any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties 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. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 with which the right or property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. 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 royaltiesroyalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a 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. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. (1. ) Royalties arising in a Contracting State and paid to a resident of the other Contracting State may shall be taxed taxable only in that other State. 2. However, State if such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient resident is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% of the gross amount of the royalties. (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 cinematograph films, recordings on tape, other media used for video or television broadcasting or other means of reproduction or transmission, any patent, trade ▇▇▇▇, 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 provisions of paragraphs 1 and 2 paragraph (1) of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 8 or Article 1415, as the case may be, shall apply. (4. ) Royalties shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which obligation to pay the royalties are paid is effectively connected, was incurred and such the royalties are borne by such that permanent establishment or fixed base, then such the royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (5. ) 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 royaltiesroyalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. (6. ) The provisions of paragraph (1) of this Article shall not apply if a the right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to a beneficially owned by the resident of the other Contracting State may shall be taxed taxable only in that other State. 2. HoweverThe term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, such royalties may also be taxed in or the Contracting State in which they arise and according right to the laws use, any copyright of that Stateliterary, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% of the gross amount of the royaltiesartistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 3. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner recipient of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base place situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseplace. In such case the provisions of Article 7 8, or Article 14, as the case may be, 15 of this Agreement shall apply. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that the Contracting State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base place in connection with which the right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseplace, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base place is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner recipient or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner recipient 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. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to whose beneficial owner is a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties 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 is a resident of the other contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including software, 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 8 or Article 1415, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such the permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, royalties 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. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. (1. ) Royalties 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 may also be by 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 royalities is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 15 per cent of the gross amount of the royaltiesroyalities. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of these limitations. (3. ) The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes for radio or television broadcasting and other means of image or sound reproduction, any patent, trademark, design or model, software, 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. (4) The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment establish ment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may beby, shall apply. 4. (5) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. (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, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. (1. ) Royalties 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 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 where such royalties are paid to a resident of the royalties other Contracting State who is subject to tax there in respect thereof the tax so charged shall not exceed 12.5% 121/2 per cent of the gross amount of the royalties. (3. ) The provisions of paragraphs 1 (1) and 2 (2) of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business has in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs perform in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. (4. ) Royalties shall be deemed to arise in a Contracting State when the payer buyer is that State itself, itself a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority or a resident of that State. WhereWhen, however, the person paying the royalties, royalty whether he is a resident of a Contracting State or not, has in a Contracting contracting State a permanent establishment or a fixed base in connection with which the right or property in respect of which liability to pay the royalties are paid is effectively connected, was incurred and such royalties are borne by such that permanent establishment or fixed base, then such the royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (5. Where) where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personpersons, the amount of the royaltiesroyalties paid, having regard to the use, use right or information for which they are paid, exceeds the amount mount which would could 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 law of each contracting State, due regard being had to the other provisions of this Agreementagreement. (6. ) The provisions of this Article shall not apply if a the right or property giving given rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. (7. ) In the this Article the term "royalties" means payments payment of any kind received as a consideration for the use of, or for the right to use, use ,any copyright copy right of literary, artistic or scientific work, any cinematograph work including cinematography films and films or tapes used for radio and television broadcastingbroadcasting :, any patent, trade ▇▇▇▇, design, model, plan, secret formula or process, process or for the use of, or the right fight to use, use industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experienceequipment.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may shall be taxed taxable only in that other State. 2. HoweverThe term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, such royalties may also be taxed in or the Contracting State in which they arise and according right to the laws use, any copyright of that Stateliterary, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% of the gross amount of the royaltiesartistic or scientific work , any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 3. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. ‌ 1. Royalties 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 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 is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of these limitations. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he the payer 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer 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. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 may also be taxed in the Contracting State in which they arise arise, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 10 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, and films or tapes for radio or television broadcasting, and other means of image or sound reproduction, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, software, or for the use of, or the right to use, industrial, commercial or scientific equipment (including ships, aircraft and containers) or for information (know- how) concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, 15 as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that Contracting State. Where, however, the person paying the such royalties, 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 right or property in respect of which obligation to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties 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 is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematographic films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.Convention.‌

Royalties. 1. Royalties arising in a one of the Contracting State and paid States, being royalties to which a resident of the other Contracting State is beneficially entitled, may be taxed in that other State. 2. However, such Such royalties may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, State but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% 15 per cent of the gross amount of the royalties. 3. Notwithstanding the provisions of paragraph 2, approved industrial royalties derived from Malaysia by a resident of Australia who is the beneficial owner thereof shall be exempt from Malaysian tax. 4. The provisions of paragraphs 1 1, 2 and 2 3 shall not apply if the beneficial owner of person beneficially entitled to the royalties, being a resident of a one of the Contracting StateStates, carries on business has in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid derived a permanent establishment with which the right, property, knowledge, information or assistance giving rise to the royalties is effectively connected with such permanent establishment or fixed baseconnected. In such a case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that Contracting State itself, itself or a political subdivision (in case of Nigeria)sub-division, a local authority, a authority or statutory body thereof or a resident of that StateState for the purposes of its tax. Where, however, the person paying the royalties, whether he is a resident of a one of the Contracting State States or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between Where the payer is related to the person beneficially entitled to the royalties and the beneficial owner or between both of them and some other person, the amount of the royaltiesroyalties paid or credited, having regard to the use, to the right to use, or to the knowledge, information or assistance, for which they are paidpaid or credited, exceeds the amount which would might be expected to have been agreed upon by the payer and the beneficial owner in the absence of such relationshipperson so entitled if they had not been related, the provisions of this Article shall apply only to the last-mentioned amount. In such that case, the excess part of the payments royalties paid or credited shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions For the purposes of this Article shall not apply paragraph, a person is related to another person if a right either person participates directly or property giving rise to indirectly in the royalties was created management, control or assigned mainly for capital of the purpose other, or if any third person or persons participate directly or indirectly in the management, control or capital of taking advantage of this Article and not for bona fide commercial reasonsboth. 7. In the Article the The term "royalties" in this Article means payments or credits of any kind received to the extent to which they are made as a consideration for - (a) the use of, or the right to use, any copyright of literary- (i) copyright, artistic or scientific work, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, design or model, plan, secret formula or process, trade ▇▇▇▇ or for the use of, other like property or the right to use, right; (ii) industrial, commercial or scientific equipment; or (iii) motion picture film or tape for radio or television broadcasting; (b) the supply of scientific, technical, industrial or commercial knowledge or information; (c) the supply of any assistance that is ancillary and subsidiary to, and is furnished as a means of enabling the application or enjoyment of, any such right or property as is described in paragraph (a)(i), any such equipment as is described in paragraph (1)(ii), or any such knowledge or information as is described in paragraph (b); or (d) total or partial forbearance in respect of the use of a property or right referred to in this paragraph. 8. The term "approved industrial royalties" in this Article means royalties as defined in paragraph 7 which are approved and certified by the competent authority of Malaysia as payable for information concerning industrialthe purpose of promoting industrial development in Malaysia and which are payable by an enterprise which is wholly or mainly engaged in activities falling within one of the following classes - (a) manufacturing, commercial assembling or scientific experienceprocessing; (b) construction, civil engineering or shipbuilding; or (c) electricity, hydraulic power, gas or water supply. 9. Royalties derived by a resident of Australia, being royalties that, as film rentals, are subject to the cinematograph film-hire duty in Malaysia, shall not be liable to Malaysian tax.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting contracting State may be taxed in that other the first mentioned State. 2. However, such royalties 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 the The tax so charged shall not exceed 12.5% (5) five percent of the gross amount of the royalties. 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 computer software, cinematograph films, or films or tapes or discs used for radio or television broadcasting), any patent, trade mark, 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 provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base with which the right or right, property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amountamount of royalties. 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. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in derived from a resident of a Contracting State and paid to by a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in from which they arise are derived and according to the laws law of that State, but if the recipient is where the beneficial owner of the royalties is subject to tax thereon in the other State, the tax so charged shall not exceed 12.5% 12.5 per cent of the gross amount of the royalties. 3. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business has in the other Contracting State in of which the company paying the royalties arise, through is a resident a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a base fixed base situated therein, and the right or of property in respect of which the royalties are paid is effectively connected with the business carried on through 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. 4. Royalties shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision (in case of Nigeria)sub-division or an administrative territorial unit, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connected, was incurred and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. 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, royalties having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-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. 6. The provisions of this Article shall not apply if a in the opinion of the competent authorities, the right or of property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the this Article the term "“royalties" ” means payments payment 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, any cinematograph work including cinematography films and or films or tapes used for radio and or television broadcasting, any patent, trade ▇▇▇▇mark, design, design or model, plan, secret formula or process, process or for the use of, or the right to use, use industrial, commercial or scientific equipment or of for information concerning industrial, commercial or scientific experience.

Royalties. (1. ) Royalties 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 may also be taxed in the Contracting State in which they arise and according to in accordance with the laws of that State, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% 10 per cent of the gross amount of the royaltiesroyalties in the meaning of paragraph 4 subparagraph a) of this Article. (3. ) However, such royalties may also be taxed in the Contracting State in which they arise and in accordance with the laws of that State, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 5 per cent of the gross amount of the royalties in the meaning of paragraph 4 subparagraph b) of this Article. (4) The term „royalties“ as used in this Article means payments of any kind received as a consideration for: a) the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films; b) any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. (5) The provisions of paragraphs 1 1, 2 and 2 3 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 4. (6) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a or local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. (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, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 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 is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% (10) percent of the gross amount of the royalties. 3. The terns "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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.a 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base with which the right or right, property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.the

Royalties. 1. Royalties 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 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, the tax so charged shall not exceed 12.5% 10 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of these limitations. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films, video recordings, and films or tapes for radio or television broadcasting), any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for the use of, or the fight to use, industrial, commercial, or scientific equipment, of for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner recipient of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base base, situated therein, and the right or property in respect of which the royalties 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. 45. Royalties shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which obligation to pay the royalties are paid is effectively connectedwas incurred, and such the royalties are borne by such that permanent establishment or fixed base, then such the royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may shall be taxed taxable only in that other State. 2. HoweverThe term „royalties“ as used in this Article means payments of any kind received as a consideration for the use of, such royalties may also be taxed in or the Contracting State in which they arise and according right to the laws use, any copyright of that Stateliterary, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% of the gross amount of the royaltiesartistic or scientific work including cinematograph films, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 3. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention.” 6. The provisions ARTICLE IX Paragraph 4 of this Article 13 (Capital gains) of the Convention shall not apply if a right or property giving rise to be replaced by the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.following paragraph:

Royalties. 1. Royalties 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 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 is a resident of the other Contracting State the tax so charged shall not exceed 12.5% 10 per cent of the gross amount of the royalties. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 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 cinematograph films and films or tapes for radio or television broadcasting), computer software, any patent, trade ▇▇▇▇, 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 (know-how) concerning industrial, commercial or scientific experience. 3. However, such royalties may also be taxed in the Contracting State in which they arise arise, and according to in accordance with the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State the tax so charged shall not exceed 12.5% 10 per cent of the gross amount of all payments. 4. Notwithstanding the provisions of paragraph 3, in the case of payment of royalties in respect of any copyright of scientific work, any patent, trade ▇▇▇▇, secret formula, process or information concerning industrial, commercial or scientific experience the tax charged shall not exceed 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 35. The provisions of paragraphs 1 1,3 and 2 4 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such a case the provisions of Article 7 or Article 14, as the case may beof this Convention, shall apply. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base with which the right or property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds 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 lastmentioned 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. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasonsConvention. 7. In Royalties shall be deemed to arise in a Contracting State when the Article payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the term "person paying the royalties" means payments , whether he is a resident of any kind received as a consideration for Contracting State or not, has in a Contracting State a permanent establishment in connection with which the use ofindebtedness on which the royalties are paid was incurred, or and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the right to use, any copyright of literary, artistic or scientific work, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, model, plan, secret formula or process, or for State in which the use of, or the right to use, industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experiencepermanent establishment is situated.

Royalties. 1. Royalties arising in a Contracting State and paid to whose beneficial owner is a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties 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 is a resident of the other contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 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 software, cinematograph films, or films or tapes and other means of image or sound reproduction, any patent, trade ▇▇▇▇, drawings, designs or models, plans, secret formulas or processes, or for the use of, or the right to use, industrial, 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such the permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may shall be taxed taxable only in that other State. 2. However, State if such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient resident is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% royalties. The competent authorities of the gross amount Contracting States shall by mutual agreement settle the mode in which the State in which the royalties arise abandons its taxation. The term "royalties" as used in this Article means payments of any kind received as a consideration for the royalties. 3use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementCon- vention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to a resident 5.1 In consideration of the other Contracting State may be taxed in that other State. 2. Howeverlicence granted hereunder, such royalties may also be taxed in the Contracting State in which they arise and according Licensee shall pay to the laws University a royalty comprised of that State, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.52% of the gross amount Revenue of the royaltiesLicensee. In addition, the Licensee shall pay to the University a royalty comprised of: (a) 20% of the first $1,000,000.00 of Sublicensing Revenue per calendar year, and (b) 10% of Sublicensing Revenue which exceeds $1,000,000.00 in each calendar year. 3. 5.2 The provisions royalty shall become due and payable within 30 days of paragraphs 1 each respective Royalty Due Date and 2 shall not apply if be calculated with respect to the beneficial owner Revenue of the royalties, being a resident of a Contracting State, carries on business Licensee and the Sublicensing Revenue in the other Contracting State three month period immediately preceding the applicable Royalty Due Date. 5.3 All payments of royalties made by the Licensee to the University hereunder shall be made in which Canadian dollars without any reduction or deduction of any nature or kind whatsoever, except as prescribed by Canadian law. 5.4 Products shall be deemed to have been sold by the royalties ariseLicensee and included in the Revenue of the Licensee when payment therefore is received by the Licensee. Sublicensing Revenue shall be deemed to have been received by the Licensee with respect to each of its sublicensees when such consideration is actually received by the Licensee from its sublicensees. 5.5 Subject to Article 1.1(n), through a permanent establishment situated thereinany transaction, disposition, or performs in other dealing involving the Technology or any part thereof between the Licensee and another person that other Contracting State independent personal services from a fixed base situated thereinis not made at fair market value shall be deemed to have been made at fair market value, and the right fair market value of that transaction, disposition, or property in respect other dealing shall be added to and deemed part of which the royalties are paid is effectively connected with such permanent establishment Revenue or fixed base. In such case the provisions of Article 7 or Article 14Sublicensing Revenue, as the case may be, shall apply. 4. Royalties be and shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base with which the right or property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise included in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason calculation of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each State, due regard being had to the other provisions of royalties under this Agreement. 6. The provisions 5.6 Without limiting the generality of this Article 5.5, if the University disputes the allocation of revenue to Readers or Samplers sold in conjunction with or as part of a Product, then the allocation of revenue between the Product and the Reader or Sampler (the "Allocation") shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this be determined in accordance with Article and not for bona fide commercial reasons5.7. 75.7 The parties shall attempt to agree upon the Allocation in a timely fashion. In the event that the parties are unable to agree upon the Allocation within 90 days of commencing efforts to negotiate same, then the parties hereto shall appoint a mutually acceptable person as an independent evaluator to conduct an evaluation to determine the Allocation. In the event that the parties cannot agree upon such an evaluator, the appointing authority shall be the British Columbia International Commercial Arbitration Centre or any successor thereto. The parties shall submit such written materials as they deem necessary to the evaluator appointed pursuant to this Article 5.7 within 30 days of his/her appointment. The evaluator appointed pursuant to this Article 5.7 shall determine the term "royalties" means payments allocation within 30 days of any kind received as a consideration for the use of, or submission of written materials by the right parties hereto and such determination shall be binding upon both parties. The cost of the evaluation pursuant to use, any copyright of literary, artistic or scientific work, any cinematograph films this Article 5.7 shall be borne 50% by the Licensee and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, model, plan, secret formula or process, or for 50% by the use of, or the right to use, industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experienceUniversity.

Royalties. 1. Royalties arising in derived from a resident of a Contracting State and paid to by a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in from which they arise are derived and according to the laws law of that State, but if the recipient is where the beneficial owner of the royalties is subject to tax thereon in the other State, the tax so charged shall not exceed 12.515% of the gross amount of the royalties. 3. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business has in the other Contracting State in of which the company paying the royalties arise, through is a resident a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with the business carried on through 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. 4. Royalties shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connected, was incurred and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the a Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of owing to a special relationship between the payer and the beneficial owner or between both of them and some other personpersons, the amount of the royalties, having regard to the use, right or information for which they are paid, 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 payment shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a the right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for reasons other than bona fide commercial reasonsconsideration. 7. In the this Article the term "royalties" means payments payment of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, any work including cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, model, plan, secret formula or process, process or for the use of, or the right to use, industrial, commercial or scientific equipment equipment, or for information concerning industrial, commercial or scientific experience.

Royalties. (1. ) Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may shall be taxed taxable only in that other State. (2. However) The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, such royalties may also be taxed in or the Contracting State in which they arise and according right to the laws use, any copyright of that Stateliterary, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% of the gross amount of the royaltiesartistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. (3. ) The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. (4. ) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (5. ) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 may also be taxed in the Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including software, cinematograph films and films or tapes for radio or television broadcasting, any patent, trade mark, design or model, plan, or secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. (1. ) Royalties 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 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 where such royalties are paid to a resident of the royalties other Contracting State who is subject to tax there in respect thereof the tax so charged shall not exceed 12.5% 12½ per cent of the gross amount of the royalties. (3. ) The provisions of paragraphs 1 (1) and 2 (2) of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business has in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. (4. ) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connected, was incurred and such royalties are borne by such that permanent establishment or fixed base, then such the royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (5. ) 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 royaltiesroyalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement. (6. ) The provisions of this Article shall not apply if a the right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. (7. ) In the this Article the term "royalties" means payments payment of any kind received as a consideration for the use of, or for the right to use, any copyright of literary, artistic or scientific work, any work including cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, model, plan, secret formula or process, or for the use of, or the right to use, use industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experienceequipment.

Royalties. (1. ) Royalties 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 may also paid for the use of immovable property or the exploitation of mines, quarries, or other natural resources shall be taxed taxable only in the Contracting States in which such property, mines, quarries, or other natural resources are situated. (2) The royalties referred to in the first sentence of paragraph (1) above may be taxed by withholding at the source in the State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% 10 percent of the gross amount of the royalties. (3. ) The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, including cinematograph and television films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or remuneration for the use of, or the right to use, agricultural, industrial, commercial or scientific equipment not constituting immovable property referred to in Article 6, or for information concerning agricultural, industrial, commercial, or scientific experience, as well as remuneration for economic or technical studies. (4) The provisions of paragraphs 1 and 2 paragraph (1) shall not apply if the beneficial owner recipient of the royalties, being a resident of a Contracting StateState has, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and with which the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseconnected. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 4. (5) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body authority thereof or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. (6) Where, by reason of a special relationship between the payer and the beneficial owner creditor or between both of them and some other person, the amount of the royalties, having regard to the use, right right, or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner creditor 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. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 may also be taxed in the Contracting State in which they arise and according to the laws of that the State, but if the recipient is recipient, being the beneficial owner of the royalties royalties, is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including software, cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-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. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 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 the tax so charged shall not exceed 12.5% of the gross amount of the royalties. 3. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base with which the right or property in respect of which the royalties are paid is effectively connected, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇mark, design, 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.

Royalties. 1. Royalties 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 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 the tax so charged shall not exceed 12.5% 7 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 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 or films or tapes or discs used for radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or a right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 1414 of this Agreement, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner of the royalties or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in derived from a resident of a Contracting State and paid to by a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in from which they arise are derived and according to the laws law of that State, but if the recipient is where the beneficial owner of the royalties is subject to tax thereon in the other State, the tax so charged shall not exceed 12.515% of the gross amount of the royalties. 3. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business has in the other Contracting State in of which the company paying the royalties arise, through is a resident a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with the business carried on through 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. 4. Royalties shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connected, was incurred and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the a Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of owing to a special relationship between the payer and the beneficial owner or between both of them and some other personpersons, the amount of the royalties, having regard to the use, right or information for which they are paid, 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-last- mentioned amount. In such that case, the excess part of the payments payment shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a the right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for reasons other than bona fide commercial reasonsconsideration. 7. In the this Article the term "royalties" means payments payment of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, any work including cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇mark, design, model, plan, secret formula or process, process or for the use of, or the right to use, industrial, commercial or scientific equipment equipment, or for information concerning industrial, commercial or scientific experience.

Royalties. 1. Royalties 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 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 is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% exceed: (a) in the case of royalties referred to in subparagraph (a) of paragraph 3 of this Article, 10 per cent of the gross amount of the royalties; (b) in the case of royalties referred to in subparagraph (b) of paragraph 3 of this Article, 10 per cent of the adjusted amount of the royalties. For the purpose of this subparagraph “the adjusted amount” means 70 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article comprises: (a) payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, including cinematograph films, and films, tapes or discs for radio or television broadcasting, or any patent, know-how, trade ▇▇▇▇, design or model, plan, secret formula or process; and (b) payments of any kind received as a consideration for the use of, or the right to use, any industrial, commercial or scientific equipment. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. , Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may shall be taxed taxable only in that other State. 2. HoweverThe term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, such royalties may also be taxed in or the Contracting State in which they arise and according right to the laws of that Stateuse, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% of the gross amount of the royaltiesany copyright or similar right, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience (know-how). 3. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 4. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base with which the right or property in respect of connection with which the obligation to pay the royalties are paid is effectively connected, was incurred and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right it was the main purpose or property giving rise to one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the royalties was created or assigned mainly for the purpose of taking are paid to take advantage of this Article and not for bona fide commercial reasonsby means of that creation or assignment. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in derived from a Contracting State and paid to by a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in from which they arise are derived and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% of the gross amount of the royalties. 3. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business has in the other Contracting State in which the royalties arise, through arise a permanent establishment situated therein, therein or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties 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. 4. Royalties shall be deemed to arise be derived in a Contracting State when where the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connected, was incurred and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. 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, person the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such that case, the excess part of the payments payment shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a the right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7▇. In the ▇▇ this Article the term "royalties" 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, any work including cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇mark, design, model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment equipment, or for information concerning industrial, commercial or scientific experience.

Royalties. 1. Royalties arising in a Contracting State and paid to a beneficial owner which is a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 10 per cent of the gross amount of the such royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematographic films and recordings on tape or other media used for radio or television broadcasting or other means of reproduction or transmission, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, and payments for the use of, or the right to use, industrial, commercial or scientific equipment. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that Contracting State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise it arises and according to the laws of that State, but if the recipient is the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.510% of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 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 4. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting Contacting State a permanent establishment or a fixed base in connection with which the right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or the fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State Party and paid to beneficially owned by a resident of the other Contracting State may Party shall be taxed taxable only in that other StateParty. 2. HoweverThe term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, such royalties may also be taxed in or the Contracting State in which they arise and according right to the laws use, any copyright of that Stateliterary, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% of the gross amount of the royaltiesartistic or scientific work including cinematograph films, any patent, trade ▇▇▇▇, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 3. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting StateParty, carries on business in the other Contracting State Party in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 4. Royalties shall be deemed to arise in a Contracting State Party when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that StateParty. Where, however, the person paying the royalties, whether he is a resident of a Contracting State Party or not, has in a Contracting State Party a permanent establishment or a fixed base in connection with which the right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State Party in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each StateContracting Party, due regard being had to the other provisions of this Agreement. 6. The provisions of Note 14: There have been no changes to this Article shall not apply if a right or property giving rise to as the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasonsMLI has no impact on it. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties 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 is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the such royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties 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 may also be taxed in the Contracting State in which they arise and according to the laws of that the State, but if the recipient is recipient, being the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including software, cinematograph films, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 45. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, Where by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. (1. ) Royalties arising in a Contracting State and paid to beneficially owned by a resident of the other Contracting State may shall be taxed taxable only in that other State. (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 cinematograph films, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. HoweverThe term „royalties” shall also include payments of any kind for the use or the right to use a person's name, such royalties may also be taxed in picture or any other similar personality rights and payments received as consideration for the Contracting State in which they arise and according to the laws recording of that State, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed 12.5% of the gross amount of the royaltiesentertainers' or sportsmen's performances by radio or television. (3. ) The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. (4. ) Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision (in case of Nigeria), a local authority, a statutory body or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connectedwas incurred, and such royalties are borne by such permanent establishment or fixed baseestablishment, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (5. ) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.

Royalties. 1. Royalties arising in derived from a resident of a Contracting State and paid to by a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in from which they arise are derived and according to the laws law of that State, but if the recipient is where the beneficial owner of the royalties is subject to tax thereon in the other State, the tax so charged shall not exceed 12.5% 12.5 per cent of the gross amount of the royalties. 3. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business has in the other Contracting State in of which the company paying the royalties arise, through is a resident a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, therein and the right or property in respect of which the royalties are paid is effectively connected with the business carried on through 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. 4. Royalties shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision (in case of Nigeria)or an administrative territorial unit, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which liability to pay the royalties are paid is effectively connected, was incurred and such royalties are borne by such permanent establishment or fixed base, base then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of owning to a special relationship between the payer and the beneficial owner or between both of them and some other personpersons, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such that case, the excess part of the payments payment shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. 6. The provisions of this Article shall not apply if a in the opinion of the competent authorities, the right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7▇. In the ▇▇ this Article the term "royalties" means payments payment 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, any work including cinematograph films and or films or tapes used for radio and or television broadcasting, any patent, trade ▇▇▇▇, design, design or model, plan, secret formula or process, process or for the use of, or the right to use, use industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience.

Royalties. 1. Royalties 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 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 the tax so charged shall not exceed 12.5% 5 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 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 motion pictures or films, recordings on tape or other media used for radio or television broadcasting or other means of 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected 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. 45. Royalties shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision (in case of Nigeria)subdivision, a local authority, a statutory body authority or a resident of that State. Where, however, the person paying the royalties, 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 right or property in respect of which obligation to pay the royalties are paid is effectively connected, was incurred and such royalties are borne by such that permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this AgreementConvention. 67. The provisions of this Article shall not apply if a the right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 7. In the Article the term "royalties" 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, any cinematograph films and films or tapes used for radio and television broadcasting, any patent, trade ▇▇▇▇, design, 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.