Common use of Where Clause in Contracts

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties interest paid, having regard to the use, right or information debt-claim for which they are it is paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to by reason of a special relationship between the payer and the recipient beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, 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 recipient beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that such case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regard to the use, right right, property or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-last- mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to by reason of a special relationship between the payer and the recipient beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, 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 recipient beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that such case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regard to the use, right right, property or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of the preceding paragraphs of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regard to the use, right or information for which they are were paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regard to the use, right or information for which they are were paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient beneficial owner or between both of them and some other person, the amount of the royalties 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 recipient beneficial owner in the absence of such relationship, the provisions of this Article article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to by reason of a special relationship between the payer and the recipient beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, 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 recipient beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, such case the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments payment shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient beneficial owner or between both of them and some other person, the amount of the royalties paid, having regard to the use, right right, property or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties or income 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to by reason of a special relationship between the payer and the recipient beneficial owner or between both of them and some other person, the amount of the royalties paidpaid 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 recipient beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that such case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient beneficial owner or between both of them and some other person, the amount of the royalties 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 recipient beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that such a case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regard to the use, the right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-last mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions provision of this ConventionAgreement.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties or sums paid, having regard to the use, right right, property or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationshiprelationship and dealing with each other at arm's length, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, paid 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, management or professional fees paid having regard to the use, right or information services for which they are it is paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-last mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regard regrad 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 recipient in the absence of such relationship, the provisions provisons of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, ; due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or of between both of them and some other person, the amount of the royalties paid, having regard to the use, right right, property or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regard to the use, use right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had has to the other provisions of this Convention.

Where. owing to by reason of a special relationship between the payer and the recipient beneficial owner or between both of them and some other person, the amount of the royalties 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 recipient beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that such case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-–mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-last- mentioned amount. In that case, the excess part of the payments payment shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain remian taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties or sums paid, having regard to the use, right right, property or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments payment shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to a by reason of special relationship between the payer and the recipient beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, 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 recipient beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that such case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable may be taxed according to the law of each Contracting State, due the regard being had to the other provisions of this ConventionAgreement.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting StateStates' own laws, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article article shall apply only to the last-last mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regard to the use, right or information for which reason why they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to in the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to in accordance with the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part par of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, State due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient therecipient or between both either of them and some other person, the amount of amountof the royalties paid, having regard to the use, use or right or information for which they whichthey are paid, exceeds the amount which would have been agreed upon by uponby the payer and the recipient in the absence of such relationship, ,the provisions of this Article shall apply only to the last-mentioned amountmentionedamount. In that such a case, the excess part of the payments shall remain taxable according to betaxable in accordance with the law laws of each the two Contracting State, due regard States dueregard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 paper and the recipient in the absence of such relationship, the provisions of this Article article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments payment shall remain taxable according to the law of each such Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient beneficial owner or between both of them and some other person, the amount of the royalties paidexceeds, 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 recipient beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient recipient, or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-last- mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this the Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regard to the use, use right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.. --------------------------------------------------------------------------------

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-last mentioned amount. In that case, the excess part of the payments shall remain taxable royalties may be taxed in the Contracting State in which the royalties arise, according to the law of each Contracting that State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regard regarding 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-last - mentioned amount. In that case, the excess part of the payments payment shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-last mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article article shall apply only to the last-mentioned latter amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, with due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this Conventionagreement.

Where. owing to by reason of a special relationship between the payer and the recipient beneficial owner or between both of them and some other person, the amount of the royalties paidroyalties, 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 recipient beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that such case, the excess part of the payments payment shall remain taxable according to the law of each Contracting State, State due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, paid 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regard to the use, right or information reason for which they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the that last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to in accordance with the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient recipient, or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-last mentioned amount. In that case, the excess part of the payments shall remain taxable be taxed according to the law laws of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In ; in that case, the excess part of the payments payment shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article article shall apply only to the last-mentioned amount. In that case, the excess part of the payments amount shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.. Article 13

Where. owing to by reason of a special relationship between the payer and the recipient beneficial owner or between both of them and some other person, the amount of the royalties paidpaid 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 recipient beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-last- mentioned amount. In that such case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regard to the use, right or information for which they these are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to by reason of a special relationship between the payer and the recipient beneficial owner of the royalties or between both of them and some other person, the amount of the royalties 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 recipient beneficial owner of the royalties in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, such case the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.. --------------------------------------------------------------------------------

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regard to the use, the right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the th e provisions of this Article shall apply only to the last-mentioned last -mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such suc h relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments payment shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law laws of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient person beneficially entitled to the royalties or between both of them and some other person, the amount of the royalties paid, having regard to the use, right or information for which what they are paidpaid for, exceeds the amount which would might have been expected to have been agreed upon by the payer and the recipient person so entitled in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments amount of the royalties paid shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient of the royalties or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable amount may be taxed according to the law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

Where. owing to a special relationship between the payer and the recipient person beneficially entitled to the royalties or between both of them and some other person, person the amount of the royalties paid, having regard to the use, right or information for which what they are paidpaid for, exceeds the amount which would might have been expected to have been agreed upon by the payer and the recipient person so entitled in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments amount of the royalties paid shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regard to the use, right or information reason for which they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Convention.

Where. owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties 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 recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.