Royalties

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....so charged shall not exceed: (a) in the case of: (i) royalties referred to in subparagraph 3(b); (ii) payments or credits for services referred to in subparagraph 3(d), subject to subparagraphs 3(h) to (l), that are ancillary and subsidiary to the application or enjoyment of equipment for which payments or credits are made under subparagraph 3(b); or (iii) royalties referred to in subparag....

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....t to use, any copyright, patent, design or model, plan, secret formula or process, trademark, or other like property or right; (b) the use of, or the right to use, any industrial, commercial or scientific equipment; (c) the supply of scientific, technical, industrial or commercial knowledge or information; (d) the rendering of any technical or consultancy services (including those of technic....

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....f the development and transfer of a technical plan or design; but that term does not include payments or credits relating to services mentioned in subparagraphs (d) and (g) that are made: (h) for services that are ancillary and subsidiary, and inextricably and essentially linked, to a sale of property; (i) for services that are ancillary and subsidiary to the rental of ships, aircraft, conta....

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....ersonal services from a fixed base situated therein, and the property, right or services in respect of which the royalties are paid or credited are effectively connected with such permanent establishment or fixed base. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that Stat....