Article 13 Royalties
     1. Subject to the provisions of paragraph 2, royalties arising in one of the States and paid to a resident of the other State shall be taxable only in that other State.
     2. Royalties paid by a company which is a resident of one of the States to a resident of the other State who holds indirectly or directly more than 50 per cent of the capital of the company making the payment may also be taxed in the first-mentioned State, but the tax shall not exceed one half of the statutory rate of assessment and shah in no case exceed 10 per cent of the gross amount of the royalties in question.
     3. The term "royalties" as used in this article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience.
     4. The provisions of paragraphs 1 and 2 shall not apply if, the recipient of the royalties, being a resident of one of the States, has in the other State in which the royalties arise a permanent establishment with which the right or property giving rise to the royalties is effectively connected. In such a case, the provisions of article 7 shall apply.
     5. Where, owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shah remain taxable according to the law of each State, due regard being had to the other provisions of this Convention.