S.L. 123.48 Art. 3owner of the in the other establishment services from a the royalties fixed base. In shall apply.

The provisions of paragraph 1 shall not apply if the beneficial royalties, being a resident of a Contracting State, carries on business Contracting State in which the royalties arise, through a permanent situated therein, or performs in that other State independent personal fixed base situated therein, and the right or property in respect of which are paid is effectively connected with such permanent establishment or such case the provisions of Article 7 or Article 14, as the case may be,