S.L. 123.48 Art. 4payer and the amount of the they are paid, payer and the of this Article part of the State, due

Where, by reason of a special relationship between the beneficial owner or between both of them and some other person, the royalties, having regard to the use, right or information for which exceeds the amount which would have been agreed upon by the beneficial owner in the absence of such relationship, the provisions shall apply only to the last-mentioned amount. In such case, the excess payments shall remain taxable according to the laws of each Contracting regard being had to the other provisions of this Agreement.

Article 13

CAPITAL GAINS