S.L. 123.38 ст. 4payer and the the amount of the the amount owner in the apply only to the shall remain being had to the

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 which would have been agreed upon by the payer and the beneficial absence of such relationship, the provisions of this Article shall last-mentioned amount. In such case, the excess part of the payments taxable according to the laws of each Contracting State, due regard other provisions of this Convention.

ARTICLE 12

Royalties