1. Royalties arising in a Contracting State and beneficially owned by a resident of the other Contracting State shall be
    taxable only in that other State.

2. 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 information concerning industrial, commercial or scientific
    experience.

3. The provisions of paragraph 1 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting
    State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment
    situated therein and the right or property in respect of which the royalties are paid is effectively connected with such
    permanent establishment. In such case the provisions of Article 7 shall apply.

4. 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 use, right or information 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.

The above information is the wording of the article dealing with the withholding tax on royalties of the tax treaty between The Netherlands and Bahrain.  Please note that the ultimate withholding tax rate may differ from the treaty rate, for instance as consequence of domestic anti-abuse legislation, provisions of the treaty protocol, etc. Before you use this information we therefore strongly recommend that you consult us to determine the accurate withholding tax rate for your specific situation. If you require our follow up, you can contact us via e-mail or call us at our offices: Ph. + 31 (10) 2010466.