S.L. 123.157 Art. 4beneficial owner business in the a permanent of which the establishment. In

The provisions of paragraphs 1 and 2 shall not apply if the of the royalties, being a resident of a Contracting State, carries on other Contracting State in which the royalties arise through establishment situated therein and the right or property in respect royalties are paid is effectively connected with such permanent such case the provisions of Article 7 shall apply.