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ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ
1984'
(ο)
The r&sident paying the interest is
a
Cypriot
cor.poration which derives
50
percent
οτ
more
ο!
ita
total gross
ίηοοωθ
from one or more permanent
estbalishments which such corporation has in the
United States.
Article
14
ROYALTIES
(1) Royalties derived from sources within a Oontracting
Stete by
a
resident
ο!
the other Contraoting State shall
be exempt frorn tax by the first-mentioned Constracting
State.
(2) The
term "royalties"
Βθ
used
ίη
this Article means:
(a)
Ρθ3ment ο!
any
kind made
ΒΒ
oonsideration for
the use of, or the right to use, copyrights of
literary, artietic, or scientific works, motion
pictures
and
works
οη
film, videotape
orσther
means
ο!
reproduction used for radio or television
broadcasting, patents, designs, models, plans,
secret processes or formulae, trademarks, or other
1ike property or rights, or knowledge, experience,
or
βki11 (k~ow);
and
(b) Gains derived from the sa1e, exchange, or
other disposition
ο!
any
such property or rights
437
to the extent that the amounts realized
οη
euch
βale,
exchange, or other diepoeition for consideration
ΒΤθ
contingent.. on the productivi ty, use, or disposi tion
οΙ
such property or right.
(3)
Paragraph (1) shall not apply if the recipient
ο!
the royalties, being a resident
ο!
a
Contracting State, has
a permanent establishment in the other Contracting State and
the property or rights giving rise to the royalties are
effectively connected with such permanent establishment.
Ιη
such a case, the provisions of Article
8
(Business ·Profits)
sha11 app1y.
(4)
Where any royalty paid by a person
to
any related
person (within the meanine
ο!
Article
11
(Related Persons»
exceeds
an amount
which
would have
been paid to
ΒΩ
unrelated