Article 11 Interest
     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. However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the person receiving such interest is a resident of the other Contracting State, the tax so charged shall not exceed 10 percent of the gross amount of the interest.
     3. Notwithstanding the provisions of Paragraph 2, interest originating in one of the Contracting States shall be exempt from tax in that State if
(a) the beneficial owner of such interest is an enterprise of the other Contracting State and the interest has not arisen from loan interest or from deposits of sums of money represented by bearer securities;
(b) such interest has arisen from loan interest or from deposits of sums of money represented by bearer securities and the beneficial owner of the interest is an enterprise of the other Contracting State which carries on a banking or insurance activity and which holds the securities in question for at least three months preceding the date of payment of the interest;
(c) such interest has arisen from business debt-claims - including those represented by bills of exchange - resulting from the forward payment of supplies of goods, products or services by enterprises;
(d) the interest is paid by reason of a loan or credit granted, guaranteed or assured as a part of a general system organized by a Contracting State, a political or administrative subdivision or local authority thereof, the NV De Nederlandsche Bank or the Banque Nationale de Belgique, whose purpose is to promote exports;
(e) such interest is paid to the other Contracting State, to a political or administrative subdivision thereof or one of its local authorities, the NV De Nederlandsche Bank or the Banque Nationale de Belgique.
     4. The term "interest" as used in this Article designates 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, other than the shares or other rights referred to in Article 10, Paragraph 7, of this Convention, and particularly income from government securities and debenture loans, including premiums of every kind attaching to said securities. Late payment penalties are not considered as interest for purposes of this Article.
     5. The provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the interest, being a resident one a Contracting State, carries on an industrial or commercial activity in the other Contracting State in which the interest arises, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the debt-claim in respect of which the interest is paid is effectively connected therewith. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply.
     6. Interest is deemed as arising in a Contracting State when the debtor is the State itself, a political subdivision, local authority or resident of that State. Where, however, the person paying the interest, whether he is a resident of one Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in the State in which the permanent establishment or fixed base is situated.
     7. 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 Convention.
     8. Notwithstanding the provisions of Paragraphs 1, 2 and 3, the interest paid by a company which, pursuant to the laws of a Contracting State, is a resident of that State, to an individual who is a resident of the other Contracting State is also taxable in the first-mentioned Contracting State and according to the laws of that State if that individual - solely or with his spouse - or one of their relatives or direct-line relations holds directly or indirectly at least five percent of subscribed capital represented by a category of shares of this company. This provision shall only apply where the individual to whom the interest is paid has, during the ten years preceding the year in which this interest is paid, been a resident of the first-mentioned State and insofar as the aforementioned shareholding-related conditions in this company were satisfied at the time this person became a resident of the other Contracting State.
     This provision shall not apply except in cases where a contribution has been assessed on the individual at the time of his emigration outside of that State, on the basis of a legal fiction of alienation of the shares referred to in the preceding paragraph and as long as a part of this contribution remains open.