ARTICLE 11
Interest
(1) Interest arising from a Contracting State whose beneficial owner is a resident of the other Contracting State, shall be liable to taxation only in that other State.
(2) The term "interest" as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor's profits, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attached to such titles. Penalties for late payments are not deemed interest for the purposes of this Article.
(3) The provisions of paragraph (1) of this Article shall not be applicable when the beneficial owner of the interest, being a resident of a Contracting State, performs economic activities in the other Contracting State from which the interest arises, maintaining a permanent establishment therein, while the credit generated by the interest is effectively connected with the aforesaid permanent establishment. In such cases, the provisions of Article 7 of this Convention shall apply.
(4) Where, by reason of a special relationship between the payer and the beneficial owner of the interest or between both of them and some other person, the amount of the interest, having due 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 cases, 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 Convention.