Article 13 - Royalties
     1. Royalties arising in a country and paid to a resident of the other country may be taxed in that other country.
     2. However, such royalties may be taxed in the country in which they arise, and according to the laws of that country, but the tax so charged shall not exceed 10 per cent of the gross amount of the royalties.
     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 a country, has in the other country 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 8 shall apply.
     5. Royalties shall be deemed to arise in a country when the payer is that country itself, a political subdivision, a local authority or a resident of that country. Where, however, the person paying the royalties, whether he is a resident of a country or not, has in a country a permanent establishment in connection with which the liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the country in which the permanent establishment is situated.
     6. 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 shall remain taxable according to the laws of each country, due regard being had to the other provisions of this Convention.