Article 12 Royalties
     1. 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. The competent authorities of the States shall by mutual agreement settle the mode in which the State in which the royalties arise abandons its taxation.
     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 paragraph 1 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 shall remain taxable according to the law of each State, due regard being had to the other provisions of this Convention.
Article 13
Limitation of Articles 10, 11 and 12
     International organisations, organs and officials thereof and members of a diplomatic or consular mission of a third State, being present in one of the States, are not entitled, in the other State, to the reductions of or exemptions from tax provided for in Articles 10, 11 and 12 in respect of dividends, interest and royalties arising in that other State, if the said items of income are not liable to a tax on income in the first-mentioned State.