EN · Physical source page 17

Original, non-operative source publication · NOT IN FORCE / NICHT IN KRAFT

Signed Berlin, 9 September 2008. Unreviewed machine transcription, not legal advice, current law or a complete current treaty chain. No human wording, alignment or publication approval.

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EN original PDF · Both source hashes and provenance · Complete 2008 source supplements

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PDF 17 · en-pdf-017-line-001- 17 -
PDF 17 · en-pdf-017-line-002Article 12
PDF 17 · en-pdf-017-line-003Royalties
PDF 17 · en-pdf-017-line-004(1) Royalties arising in a Contracting State and paid to a resident of the other Contracting
PDF 17 · en-pdf-017-line-005State shall be taxable only in that other State‚ provided such resident is the beneficial
PDF 17 · en-pdf-017-line-006owner of the royalties.
PDF 17 · en-pdf-017-line-007(2) The term ”royalties” as used in this Article means payments of any kind received as
PDF 17 · en-pdf-017-line-008a consideration for the use of‚ or the right to use‚ any copyright of literary‚ artistic or
PDF 17 · en-pdf-017-line-009scientific work including cinematograph films and films‚ tapes or discs for radio or
PDF 17 · en-pdf-017-line-010television broadcasting‚ any patent‚ trade mark‚ design or model‚ plan‚ secret formula or
PDF 17 · en-pdf-017-line-011process‚ or for information concerning industrial‚ commercial or scientific experience.
PDF 17 · en-pdf-017-line-012(3) The provisions of paragraph 1 shall not apply if the beneficial owner of the royalties‚
PDF 17 · en-pdf-017-line-013being a resident of a Contracting State‚ carries on business in the other Contracting State
PDF 17 · en-pdf-017-line-014in which the royalties arise‚ through a permanent establishment situated therein and the
PDF 17 · en-pdf-017-line-015right or property in respect of which the royalties are paid is effectively connected with
PDF 17 · en-pdf-017-line-016such permanent establishment. In such case‚ the provisions of Article 7 shall apply.
PDF 17 · en-pdf-017-line-017(4) Royalties shall be deemed to arise in a Contracting State when the payer is a resident
PDF 17 · en-pdf-017-line-018of that State. Where‚ however‚ the person paying the royalties‚ whether that person is a
PDF 17 · en-pdf-017-line-019resident of a Contracting State or not‚ has in a Contracting State a permanent
PDF 17 · en-pdf-017-line-020establishment in connection with which the liability to pay the royalties was incurred‚ and
PDF 17 · en-pdf-017-line-021such royalties are borne by such permanent establishment‚ then such royalties shall be
PDF 17 · en-pdf-017-line-022deemed to arise in the Contracting State in which the permanent establishment is situated.
PDF 17 · en-pdf-017-line-023(5) Where‚ by reason of a special relationship between the payer and the beneficial owner
PDF 17 · en-pdf-017-line-024or between both of them and some other person‚ the amount of the royalties‚ having
PDF 17 · en-pdf-017-line-025regard to the use‚ right or information for which they are paid‚ exceeds the amount which
PDF 17 · en-pdf-017-line-026would have been agreed upon by the payer and the beneficial owner in the absence of