Singapore - Royalty

Article 12. Royalties

1.  Subject to the provisions of paragraph 6, royalties arising in one of the States and paid to a resident of the other State shall be taxable only in that other State.

2.  Subject to the provisions of paragraph 6, sums from the alienation of any right or property giving rise to royalties shall be taxable only in the State of which the alienator is a resident. 

3.  The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of scientific work, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. 

4.  The provisions of paragraphs 1 and 2 shall not apply if the recipient of the royalties or sums being a resident of one of the States, has in the other State in which the royalties or sums arise a permanent establishment with which the right or property giving rise to the said income is effectively connected. In such a case, the provisions of Article 7 shall apply. 

5.  Where, owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regard to the use, right, property or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of the preceding paragraphs of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each State, due regard being had to the other provisions of this Convention. 

6.  This Convention shall not apply to payments of any kind received as a consideration for the use of, or for the right to use, any copyright of literary or artistic work, including motion picture films and tapes for television or broadcasting, or to sums from the alienation of any right or property giving rise to such payments.