Article 12 Royalties
     1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State shall only be taxable in that other State, if this resident is the beneficial owner thereof.
     2. The term "royalties" as used in this Article designates 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 cinematographic films and recording tapes, of any patent, trade mark, design or model, plan, secret formula or process as well as for the use of, or the right to of use, any industrial, commercial, or scientific equipment or for information concerning experience acquired in the industrial, commercial, or scientific sector.
     3. The provisions of Paragraph 1 shall not apply if the beneficial owner of the royalties, being a resident of one Contracting State, carries on an activity in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected therewith. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply.
     4. The royalties are deemed to arise in a Contracting State in case the payer is itself that State, a political subdivision, a local authority or a resident of that State. However, in case the payer of the royalties, whether a resident of a Contracting State or not, has a permanent establishment or a fixed base in a Contracting State for which the contract giving rise to the payment of the royalties has been entered and which as such incurs the charge thereof, these royalties are deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated.
     5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the service for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention.