DT8406 - DT: Grenada: double taxation agreement, Article 7: Royalties

(1) Any royalty derived from sources within one of the territories by a resident of theother territory who is subject to tax in that other territory in respect thereof and isnot engaged in trade or business in the first-mentioned territory through a permanentestablishment situated therein, shall be exempt from tax in that first-mentionedterritory; but no exemption shall be allowed under this paragraph in respect of so much ofany royalty as exceeds an amount which represents a fair and reasonable consideration forthe rights for which the royalty is paid.

(2) In this paragraph the term royalty means any royalty or other amount paid asconsideration for the use of, or for the privilege of using, any copyright, patent,design, secret process or formula, trade-mark, or other like property, but does notinclude a royalty or other amount paid in respect of the operation of a mine or quarry orof other extraction of natural resources.