S.L. 123.105 Art. 5the payer is a whether he is a permanent to pay the permanent arise in the State

Royalties shall be deemed to arise in a Contracting State when resident of that State. Where, however, the person paying the royalties, a resident of a Contracting State or not, has in a Contracting State establishment or a fixed base in connection with which the liability royalties was incurred, and such royalties are borne by such establishment or fixed base, then such royalties shall be deemed to in which the permanent establishment or fixed base is situated.