S.L. 123.109 Art. 4derives profits impose any tax are paid to a resident of that are paid is situated in that on the com undistributed other State. 1. Contracting 2. The every kind, to participate securities and attaching to shall not be 3. The interest, being Contracting situated fixed base is effectively case the sh

Where a company which is a resident of a Contracting State or income from the other Contracting State, that other State may not on the dividends paid by the company, except insofar as such dividends other State or insofar as the holding in respect of which the dividends effectively connected with a permanent establishment or a fixed base other State, nor subject the company’s undistributed profits to a tax pany's undistributed profits, even if the dividends paid or the profits consist wholly or partly of profits or income arising in such

Article 11 INTEREST Interest arising in a Contracting State and paid to a resident of the other State shall be taxable only in that other State. term "interest" as used in this Article means income from debt-claims of whether or not secured by mortgage and whether or not carrying a right in the debtor’s profits, and in particular, income from government income from bonds or debentures, including premiums and prizes such securities, bonds or debentures. Penalty charges for late payment regarded as interest for the purpose of this Article. provisions of paragraph 1 shall not apply if the beneficial owner of the a resident of a Contracting State, carries on business in the other State in which the interest arises, through a permanent establishment therein, or performs in the other State independent personal services from a situated therein and the debt-claim in respect of which the interest is paid connected with such permanent establishment or fixed base. In such provisions of Article 7 or Article 14 of this Agreement, as the case may be,

Interest shall be deemed to arise in a Contracting State when the payer is a State. Where, however, the person paying the interest, whether he is a Contracting State or not, has in a Contracting State a permanent or a fixed base in connection with which the indebtedness on which is paid was incurred, and such interest is borne by such permanent or fixed base, then such interest shall be deemed to arise in the State in permanent establishment or fixed base is situated. by reason of a special relationship between the payer and the owner or between both of them and some other person, the amount of the having regard to the debt-claim for which it is paid, exceeds the amount have been agreed upon by the payer and the beneficial owner in the such relationship, the provisions of this Article shall apply only to the amount. In such case, the excess part of the payments shall remain according to the laws of each Contracting State, due regard being had to the provisions of this Agreement. Article 12

ROYALTIES Royalties arising in a Contracting State and beneficially owned by a resident Contracting State shall be taxable only in that other State. term "royalties" as used in this Article means payments of any kind a consideration for the use of, or the right to use, any copyright of artistic or scientific work including cinematograph films, any patent, trade or model, plan, secret formula or process, or for information industrial, commercial or scientific experience.