(2) However, such royalties may also be taxed in the Con-
tracting State in which they arise and according to the laws of
that State, but if the beneficial owner of the royalties is a resi-
dent of the other Contracting State, the tax so charged shall not
exceed 8 per cent of the gross amount of the royalties.
(3) The term “royalties” as used in this Article means pay-
ments 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, and films or tapes for radio
or television broadcasting, 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 above shall not
apply if the beneficial owner of the royalties, being a resident of
a Contracting State, carries on business in the other Contract-
ing State in which the royalties arise, through a permanent
establishment situated therein, or performs in that other State
independent personal services from a fixed base situated there-
in, and the right or property in respect of which the royalties are
paid is effectively connected with such permanent establish-
ment or fixed base. In such case the provisions of Article 7 or
Article 14, as the case may be, shall apply.
(5) Royalties shall be deemed to arise in a Contracting State
when the payer is that State itself, a Land, a political sub-
division, a local authority or a resident of that State. Where,
however, the person paying the royalties, whether he is a re-
sident of a Contracting State or not, has in a Contracting State
a permanent establishment or a fixed base in connection with
which the liability to pay the royalties was incurred, and such
royalties are borne by such permanent establishment or fixed
base, then such royalties shall be deemed to arise in the Con-
tracting State in which the permanent establishment or fixed
base is situated.
(6) 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-men-
tioned 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
Agreement.
de-singapore-2006-base | BGBl. 2006 II S. 930 | Signed: 2004-06-28 | Gazette publication: 2006-11-03
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-singapore-2006-base/. PDF page links identify pages, not verified paragraph correspondence.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown. No current-law consolidation, effective-period determination, MLI application, or complete amendment-chain verification has been performed. Original publication year is not a current applicability date. Original signed-2004/published-2006 edition omits the 2019 amendment and 2021 notification ordinance. Not listed in roster I.2; this is snapshot evidence only, not proof of no MLI relevance forever.
Protocols and later instruments
The protocol printed with this agreement is separately preserved in source supplements; it has not been merged into treaty articles. Subsequent protocols, amendments, MLI effects, replacements and suspensions are unresolved. This is not a consolidated current-law instrument. Source-triage warnings: Original signed-2004/published-2006 edition omits the 2019 amendment and 2021 notification ordinance. Not listed in roster I.2; this is snapshot evidence only, not proof of no MLI relevance forever. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2019-12-09; citation: BGBl. 2020 II S. 1178; BGBl. 2021 II S. 437; entry into force: 2021-03-29; general application: 2022-01-01 / domestic-notification-ordinance; citation: BGBl. 2021 I S. 5218; entry into force: 2021-12-23
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 2006 II S. 930 | de-singapore-2006-base | de-singapore-2006-base | BGBl. 2006 II S. 930 | Signed: 2004-06-28 | Gazette publication: 2006-11-03 | Article 12 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-singapore-2006-base/en/articles/article-12/
Source, edition and limits
Source edition
de-singapore-2006-base | BGBl. 2006 II S. 930 | Signed: 2004-06-28 | Gazette publication: 2006-11-03
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-singapore-2006-base/. PDF page links identify pages, not verified paragraph correspondence.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown. No current-law consolidation, effective-period determination, MLI application, or complete amendment-chain verification has been performed. Original publication year is not a current applicability date. Original signed-2004/published-2006 edition omits the 2019 amendment and 2021 notification ordinance. Not listed in roster I.2; this is snapshot evidence only, not proof of no MLI relevance forever.
Protocols and later instruments
The protocol printed with this agreement is separately preserved in source supplements; it has not been merged into treaty articles. Subsequent protocols, amendments, MLI effects, replacements and suspensions are unresolved. This is not a consolidated current-law instrument. Source-triage warnings: Original signed-2004/published-2006 edition omits the 2019 amendment and 2021 notification ordinance. Not listed in roster I.2; this is snapshot evidence only, not proof of no MLI relevance forever. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2019-12-09; citation: BGBl. 2020 II S. 1178; BGBl. 2021 II S. 437; entry into force: 2021-03-29; general application: 2022-01-01 / domestic-notification-ordinance; citation: BGBl. 2021 I S. 5218; entry into force: 2021-12-23
Text language and status
en · authentic-language-transcription · machine-transcription