Royalties

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.... owner of the royalties, the tax so charged shall not exceed 1[ten per cent (10%)] 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 broadc....

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....ons of Article 7 or Article 16, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State where the payer is that Contracting State itself, a political sub-division, a local authority or a resident of that Contracting State. However, where the person paying the royalties, whether he is a resident of a Contracting State or not, has in that Contracting State a pe....