(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 12 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, any patent, trade mark,
design or model, plan, secret formula or process, or for informa-
tion concerning industrial, commercial or scientific experience.
The term “royalties” shall also include payments of any kind for
the use or the right to use a person’s name, picture or any other
similar personality rights and on payments received as consid-
eration for the registration of entertainers’ or sportsmen’s per-
formances by radio or television.
(4) The provisions of paragraphs 1 and 2 shall not apply if the
beneficial owner of the royalties, being a resident of a Contract-
ing State, carries on business in the other Contracting 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 therein, and the
right or property in respect of which the royalties are paid is
effectively connected with such permanent establishment or
fixed base. In such case the provisions of Article 7 or 14 shall
apply.
(5) Royalties shall be deemed to arise in a Contracting State
when the payer is a resident of that State. Where, however, the
person paying the royalties, whether he is a resident of a Con-
tracting State or not, has in a Contracting State a permanent
establishment or a fixed base in connection with which the lia-
bility 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 Contracting 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-syria-2010-base | BGBl. 2010 II S. 1359 | signed 2010-02-17 | published 2010-11-23 | Signed: 2010-02-17 | Gazette publication: 2010-11-23
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
This source supplies German and English versions. The signing clause also identifies Arabic as authentic; that third version is NOT present in this reader. Missing here does not mean globally unavailable. 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-syria-2010-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 as current law. Signed 2010-02-17; consent law 2010-11-18; gazette publication 2010-11-23. Edition ID year is not a signature date. Treaty entry into force: not resolved as a single source-bound field by the retained audit. Roster general application: 2011-01-01 (not a universal tax-specific rule). Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Protocols and later instruments
Printed signature protocol retained separately and not merged into articles. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 2010 II S. 1359 | de-syria-2010-base | de-syria-2010-base | BGBl. 2010 II S. 1359 | signed 2010-02-17 | published 2010-11-23 | Signed: 2010-02-17 | Gazette publication: 2010-11-23 | Article 12 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-syria-2010-base/en/articles/article-12/
Source, edition and limits
Source edition
de-syria-2010-base | BGBl. 2010 II S. 1359 | signed 2010-02-17 | published 2010-11-23 | Signed: 2010-02-17 | Gazette publication: 2010-11-23
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
This source supplies German and English versions. The signing clause also identifies Arabic as authentic; that third version is NOT present in this reader. Missing here does not mean globally unavailable. 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-syria-2010-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 as current law. Signed 2010-02-17; consent law 2010-11-18; gazette publication 2010-11-23. Edition ID year is not a signature date. Treaty entry into force: not resolved as a single source-bound field by the retained audit. Roster general application: 2011-01-01 (not a universal tax-specific rule). Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Protocols and later instruments
Printed signature protocol retained separately and not merged into articles. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Text language and status
en · authentic-language-transcription · machine-transcription