S.L. 123.67 Art. 4owner business in the a permanent personal in respect of permanent Article 14, as

The provisions of paragraphs 1 and 2 shall not apply if the beneficial of the royalties, being a resident of a Contracting State, carries on other Contracting State in which the royalties arise, through establishment situated therein, or performs in that other State independent services from a fixed base situated therein, and the right or property which the royalties are paid is effectively connected with such establishment or fixed base. In such case the provisions of Article 7 or the case may be, shall apply.