Royalties

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ts or credits are made under subparagraph 3(b); or (iii) royalties referred to in subparagraph 3(f) that relate to equipment mentioned in subparagraph 3(b): 10 percent of the gross amount of the royalties; and (b) in the case of other royalties: (i) during the first 5 years of income for which this Agreement has effect: A. where the payer is the Government or a political subdivision of that State or a public sector company: 15 percent of the gross amount of the royalties; and B. in all other cases: 20 percent of the gross amount of the royalties; and (ii) during all subsequent years of income: 15 percent of the gross amount of the royalties. 3. The term "royalties" in this Ar....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....lan 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, containers or other equipment used in connection with the operation of ships or aircraft in international traffic; (j) for teaching in or by an educational institution; (k) for services for the personal use of the individual or individuals making the payments or credits; or (l) to an employee of the person making the payments or credits or to any....