Interest

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....mount of the interest in all other cases.] 3. Notwithstanding the provisions of paragraphs 1 and 2 : ^2[(a) interest arising in Contracting State and paid to the Government of the other Contracting State, a political subdivision or local authority thereof, the Central Bank or any agency (including a financial institution) wholly owned by that Government or political subdivision shall be exempt from tax in the first-mentioned State, unless subparagraph b) applies;] (b) interest from securities, bonds or debentures issued by the Government of a Contracting State, a political sub-division thereof or any agency (including a financial institution) wholly owned by that Government or political sub-division shall be taxabl....

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....e. Where, however, the person paying the interest, whether he is a resident of a 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.] 8. Where, by a 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....