Page:United States Statutes at Large Volume 60 Part 2.djvu/296

 [60 STAT. Royalties, etc. Rate of tax on roy- alties. tax on such interest and not engaged in trade or business in the United States, shall be exempt from United States tax; but such exemption shall not apply to such interest paid by a United States corporation to a corporation resident in the United Kingdom controlling, directly or indirectly, more than 50 percent of the entire voting power in the paying corporation. (2) Interest (on bonds, securities, notes, debentures, or on any other form of indebtedness) derived from sources within the United Kingdom by a resident of the United States who is subject to United States tax on such interest and not engaged in trade or business in the United Kingdom, shall be exempt from United Kingdom tax; but such exemp- tion shall not apply to such interest paid by a corporation resident in the United Kingdom to a United States corporation controlling, di- rectly or indirectly, more than 50 percent of the entire voting power in the paying corporation. ARTICLE VIII (1) Royalties and other amounts paid as consideration for the use of, or for the privilege of using, copyrights, patents, designs, secret pro- cesses and formulae,trade-marks, and other like property, and derived from sources within the United States by a resident of the United Kingdom who is subject to United Kingdom tax on such royalties or other amounts and not engaged in trade or business in the United States, shall be exempt from United States tax. (2) Royalties and other amounts paid as consideration for the use of, or for the privilege of using, copyrights, patents, designs, secret pro- cesses and formulae, trade-marks, and other like property, and derived from sources within the United Kingdom by a resident of the United States who is subject to United States tax on such royalties or other amounts and not engaged in trade or business in the United Kingdom, shall be exempt from United Kingdom tax. (3) For the purposes of this Article the term "royalties" shall be deemed to include rentals in respect of motion picture films. ARTICLE IX (1) The rate of United States tax on royalties in respect of the operation of mines or quarries or of other extraction of natural re- sources, and on rentals from real property or from an interest in such property, derived from sources within the United States by a resident of the United Kingdom who is subject to United Kingdom tax with respect to such royalties or rentals and not engaged in trade or business in the United States, shall not exceed 15 percent: Provided that any such resident may elect for any taxable year to be subject to United States tax as if such resident were engaged in trade or business in the United States. (2) Royalties in respect of the operation of mines or quarries or of other extraction of natural resources, and rentals from real property or from an interest in such property, derived from sources within the United Kingdom by an individual who is (a) a resident of the United 1382 TREATIES

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