8. pants

A resident of a Contracting

State may be subject to tax in the other Contracting State in

respect of interest expenses allocable to its profits

attributable to a permanent establishment in the other

Contracting State or subject to tax in the other Contracting

State under Article 6 (Income from Immovable (Real) Property) or

paragraph 1 of Article 13 (Capital Gains) over the interest paid

by or from that permanent establishment or trade or business. In

this case, the allocable interest expense in excess of interest

paid shall be deemed to be interest arising in the other

Contracting State and be beneficially owned by a resident of the

first-mentioned Contracting State.

ARTICLE 12

Royalties