S.L. 123.103 Art. 8payer and the the amount of the the amount other provisions 1. Royalties Contracting State 2. However, they arise and owner of the amount of the 3. The term received as a literary, artistic mark, design or to use, industrial, industrial, 4. The of the royalties, other establishment services from a w

Where, by reason of a special relationship between the beneficial owner or between both of them and some other person, interest, having regard to the debt-claim for which it is paid, exceeds of this Agreement. Article 12 ROYALTIES

arising in a Contracting State and paid to a resident of the other may be taxed in that other State.

such royalties may also be taxed in the Contracting State in which according to the laws of that State, but if the recipient is the beneficial royalties, the tax so charged shall not exceed 10 per cent of the gross royalties. "royalties" as used in this Article means payments of any kind consideration for the use of, or the right to use, any copyright of or scientific work including cinematograph films, any patent, trade model, plan, secret formula or process, or for the use of, or the right commercial or scientific equipment, or for information concerning commercial or scientific experience.

provisions of paragraphs 1 and 2 shall not apply if the beneficial owner being a resident of a Contracting State, carries on business in the Contracting State in which the royalties arise, through a permanent situated therein, or performs in that other State independent personal fixed base situated therein, and the right or property in respect of royalties are paid is effectively connected with such permanent fixed base. In such case the provisions of Article 7 or Article 14, as shall apply.

shall be deemed to arise in a Contracting State when the payer is a political subdivision, a local authority, a statutory body or a State. Where, however, the person paying the royalties, whether he is Contracting State or not, has in a Contracting State a permanent fixed base in connection with which the liability to pay the royalties such royalties are borne by such permanent establishment or fixed royalties shall be deemed to arise in the Contracting State in which establishment or fixed base is situated.

by reason of a special relationship between the payer and the or between both of them and some other person, the amount of the regard to the use, right or information for which they are paid, amount which would have been agreed upon by the payer and the in the absence of such relationship, the provisions of this Article to the last-mentioned amount. In such case, the excess part of the remain taxable according to the laws of each Contracting State, due to the other provisions of this Agreement.

Article 13 CAPITAL GAINS derived by a resident of a Contracting State from the alienation of property referred to in Article 6 and situated in the other Contracting taxed in that other State.