ARTICLE 11
Interest
(1) Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed only in that other State.
(2) The term "interest" as used in this Article means income from government securities, bonds or debentures, whether or not secured by mortgage and whether or not carrying a right to participate in profits, and from debt-claims of every kind, as well as all other income which is subjected to the same taxation treatment as income from loans by the laws of the State in which it arises.
(3) The provisions of paragraph (1) shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, has in the other Contracting State in which the interest arises a permanent establishment, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment. In such case Article 7 shall apply.
(4) Where, by reason of a special relationship between the payer and the recipient or between both of them and some other person, the amount of interest paid, 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 recipient 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 may be taxed according to the laws of each Contracting State, due regard being had to the other provisions of this Convention.