Direct Tax Avoidance Agreements

UAR (Egypt)

Article XIII - Royalties - 1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable only in the first mentioned State.

2. 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 literary, artistic or 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 equipments or for information concerning industrial, commercial or scientific experience but does not include any royalty or other like amount in respect of the operation of mines, quarries or any other place of extraction of natural resources.

3. Rents and royalties arising in a Contracting State in respect of cinematographic films and paid to a resident of the other Contracting State shall be taxable only in the first-mentioned State according to the tax laws of that state.

4. The provisions of this article shall not apply where founders shares are issued in the United Arab Republic as a consideration for the rights mentioned in paragraph (2) of this article and taxed in accordance with the provisions of article 1 of Law 14 of 1939. In such event article XI of this Convention shall be applicable.

5. Royalty shall be deemed to arise in a Contracting State when the payer is that State itself, a political sub-division, a local authority or a resident of that State.