Royalties

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....ent is the beneficial 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 ra....

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.... In such case, the provisions 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....