ARTICLE 11
Interest
(1) Interest arising in a Contracting State and paid to a resident of the other Contracting State may only be taxed in that other State.
(2) Subject to the provisions of Article 10 paragraph 4, the term "interest" as used in this Article means income from government securities, bonds, or debentures including convertible bonds, whether or not carrying a right to participate in the debtor's profits, and income from debt-claims of every kind, as well as all other income which under the tax law of the State in which it originates is regarded as income from loans.
(3) The provisions of paragraph 1 shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent establishment situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply.
(4) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.