Article 11 Interest
     1. Interest arising in one of the States which is derived and beneficially owned by a resident of the other State shall be taxable 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 attaching to such securities, bonds or debentures but 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.
     3. The provisions of paragraph 1 of this Article 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.
     4. Where, owing to a special relationship between the payer and the beneficial owner or between both of them and some other person the amount of the interest paid exceeds the amount of interest which would have been determined, taking into consideration the terms and amount of the debt-claim 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 of interest. In that 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.
     5. Any provision in the law of one of the States relating only to interest paid to a non-resident company shall not operate so as to require such interest paid to a resident of the other State to be treated as a distribution made by the company paying such interest or to be left out of account as a deduction in computing the taxable profits of the company paying the interest. The preceding sentence shall not apply to interest paid by a resident of one of the States to a company resident in the other State, more than 50 per cent of the voting power in which is controlled, directly or indirectly, by a person or persons who are residents of the first-mentioned State.
     6. The provisions of this Article shall not apply if the debt-claim in respect of which the interest is paid was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons.