TaxTMI 
TaxTMI 
Article 12 - Royalties
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....ra 1 of Article 12 * 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 and * the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. * In such case the provi....
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....icle 12 ] Definition of Royalties * "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 including cinematograph films, * any patent, trade mark, design or model, plan, secret formula or process, or * for information concerning industrial, commercial or scientific experience. [ ....
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....imitation. [ Para 2 of Article 12 ] Exception of Para 1 and 2 of Article 12 * 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 State independent personal services from a fixed base situated ther....
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....by such permanent establishment or fixed base, * then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. [ Para 5 of the Article 12 ] Definition of Royalties * "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 i....