Article 11 Interest
     1. Interest arising in one of the States and paid to a resident of the other State may be taxed in that other State.
     2. However, such interest may also be taxed in the State in which it arises and according to the laws of that State, but if the recipient is the beneficial owner of the interest the tax so charged shall not exceed:
(a) 10 per cent of the gross amount of the interest if the interest is received by a bank or other financial institution;
(b) 15 per cent of the gross amount of the interest if the interest is paid by a company to a company (other than a partnership) which holds directly at least 25 per cent of the capital of the paying company;
(c) 10 per cent of the gross amount of the interest if the interest is received in virtue of a contract of financing or of delay in payment relating to the sale of industrial, commercial or scientific equipment or to the construction of industrial, commercial or scientific installations as well as of public works;
(d) 20 per cent of the gross amount of the interest in all other cases.
     3. Notwithstanding the provisions of paragraph 2:
(a) the State Bank of Pakistan shall be exempt from Netherlands tax with respect to interest arising in the Netherlands;
(b) the Central Bank of the Netherlands shall be exempt from Pakistan tax with respect to interest arising in Pakistan;
(c) the Government of one of the States shall be exempt from the tax of the other State with respect to interest arising in that other State, if such interest is derived from loans;
(d) any financial institution owned or controlled by the Government of one of the States shall be exempt from tax of the other State with respect to interest arising in that other State, if such interest is derived from loans.
     4. 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 attaching to such securities, bonds or debentures. However, this term does not include income dealt with in Article 10. Penalty charges for late payment shall not be regarded as interest for the purpose of this Article.
     5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the interest, being a resident of one of the States, carries on business in the other 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 with such permanent establishment or fixed base. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply.
     6. Interest shall be deemed to arise in one of the States when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the interest, whether he is a resident of one of the States or not, has in one of the States 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 State, due regard being had to the other provisions of this Convention.