Article 12 Royalties
     1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable in that other State.
     2. The taxation of royalties arising in a Contracting State, in situations where the beneficial owner is entitled to royalties, may not exceed 11 percent of the gross amount of said royalties, in accordance with the laws of the State.
     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 cinematography 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 (with the exception of payments for the lease of ships and aircraft used in international transport), and for information concerning industrial, commercial or scientific experience, as well as for economic research or for technical services given in the State where the payments arise.
     4. The provisions or paragraph 1 shall not apply if the recipient of the royalties, being a resident of a Contracting State, has in the other Contracting State in which the royalties arise a permanent establishment, or performs independent work in the other State from a fixed base, with which the right or property giving rise to the royalties is effectively connected. In such a case, the provisions of article 7 and article 14 shall apply.
     5. Royalties are deemed to arise from a Contracting State if they are paid by the State, by a political subdivision, by a local authority, or by a resident of the State. However, if the person paying the royalties, whether he is a resident of a Contracting State or not, has a permanent establishment or a fixed base in a Contracting State for which a contract was made for which royalties were paid, and these royalties originate from the permanent establishment or fixed base, these royalties are considered to arise from the State where the permanent establishment or fixed base is located.
     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 latter amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, with due regard to the other provisions of this Convention.