TaxTMI 
TaxTMI 
Article 11 - Interest
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....ed in that State according to the laws of that State, * if the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not exceed 10% of the gross amount of the interest. * The UN Model Tax Convention leaves this percentage to be established through bilateral negotiations. * The competent authorities of the Contracting States shall by mutual ag....
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....t, 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 ....
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....ge and * whether or not carrying a right to participate in the debtor's profits, and * income from government securities and * income from bonds or debentures, * including premiums and prizes attaching to such securities, bonds or debentures. * Exclude - Penalty charges for late payment shall not be regarded as interest for the purpose of this Article. [ Para 3 of Article 11 ] * Defini....
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....r with * (b) business activities referred to in (c) of paragraph 1 of Article 7. * In such cases the provisions of Article 7 or Article 14, as the case may be, shall apply. [ Para 4 of Article 11 ] "Interest" Deemed to be arise in Contracting State * Interest shall be deemed to arise in a Contracting State when the payer is a resident of that State. * Where, the person paying ....