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Article 3: State of residence of the beneficiary
1. For the purposes of this Convention, the State of which the beneficiary of the copyright
royalties is a resident shall be deemed to be the State of residence of the beneficiary.
2. A person shall be deemed to be a resident of a State if he is liable to tax therein by
reason of his domicile, residence, place of effective management or any other relevant
criterion as agreed to in a bilateral agreement concerning double taxation of copyright
royalties. But this term does not include any person who is liable to tax in that State in
respect only of income from sources in that State as capital he possesses there.
Article 4: State of source of royalty
For the purposes of this Convention, a State shall be deemed to be the State of source of
copyright royalties when such royalties for the use of, or the right to use, a copyright in a
literary, artistic or scientific work are originally due:
(a)by that State or by a political or administrative subdivision or local authority of that State;
(b)by a resident of that State except where they result from an activity carried on by him in
another State through a permanent establishment or from a fixed base;
(c)by a non-resident of that State, where they result from an activity carried on by him
through a permanent establishment or from a fixed base.
Chapter II: Guiding principles for action against double taxation of copyright royalties
Article 5: Fiscal sovereignty and equality of rights of States
Action against double taxation of copyright royalties shall be carried out, in accordance with
the provisions of Article 8 of this Convention, with due respect for the fiscal sovereignty of
the State of source and the State of residence, and due respect for the equality of their right
to tax these royalties.
Article 6: Fiscal non-discrimination
The measures against double taxation of copyright royalties shall not give rise to any tax
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