S.L. 123.95 Art. 5the payer is a whether the State a the obligation to such 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, payer is a resident of a Contracting State or not, has in a Contracting permanent establishment or a fixed base in connection with which pay the royalties was incurred, and such royalties are borne by establishment or fixed base, then such royalties shall be deemed to in which the permanent establishment or fixed base is situated.