(1) Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
(2) The term "interest", as used in this Article means income from debt claims of any kind, regardless of whether or not secured by mortgage and whether or not carrying a right to participate in debtors profits, and in particular, income from government securities and income from bonds or debentures including premiums and prizes attached to such securities, bonds or debentures. Penalties for late payment shall not be regarded as interest for the purpose of this Article. The term "interest" however does not include the earnings treated in Article 10.
(3) The provisions of paragraphs (1) of this Article shall not apply if the recipient of interest, being a resident of a Contracting State, carries on business activities in the other Contracting State in which the interest arises, through a permanent establishment situated therein or renders in the other State independent personal services from a fixed base situated therein and the debt claims on the basis of which the interest is paid are effectively connected to such permanent establishment or fixed base. In such a case, the provisions of Article 7 of this Convention, as the case may be, shall.
(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 interest, having regard to the debt claims for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner of such interest, in the absence of such special relationship, then the provisions of this Article shall apply only to the last mentioned amount. In such a case, the excess part of the payments shall remain taxable in accordance with the laws of each Contracting State, due regard being had to the other provisions of this Convention.