Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, third person, the amount of the royalties, having regard to the use for which they are paid, exceeds 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 . In this case, the excess part of the payments taxable according to the laws of each Contracting State, due regard being had to the this Convention.
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 inter- est, having regard to the debt-claim for which it is 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 re- gard being had to the other provisions of this Agreement.
Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties or fees for technical services, having regard to the use, right or information 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.
