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 be taxed in the State in which it arises, but the tax so charged shall not exceed: a) 10 percent of the gross amount of the interest, if the interest is derived by a bank or any other financial institution (including an insurance company) which is a resident of the other State; b) 25 percent of the gross amount of the interest, in all other cases. 3. The competent authorities of the States shall settle the mode of application of paragraph 2. 4. The term "interest" as used in this Article means income from Governement securities bonds or debentures, whether or not secured by mortgage and whether or not carrying a right to participate in profits, and debt- chaims of every kind as well as all other income from money lent by the taxation law of the State in which the income arises. 5. The provisions of paragraphs 1 and 2 shall not apply if the recipient of the interest, being a resident of one of the States, has in the other State in which the interest arises, a permanent establishment with which the debt-claim from which the interest arises is effectively connected. In such a case, the provisions of Article 7 shall apply, provided that under the law of that other State the interest is taxed as part of the profits of that permanent establishment. 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 is one of the States a permanent establishment in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such, permanent establishment, then such interest shall be deemed to arise in the State in which the permanent establishment is situated. 7. Where, owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the interest paid, 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 recipient in the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each State, due regard being had to the other provisions of this Convention. ARTICLE 12
ROYALTIES 1. Royalties 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 royalties may be taxed in the State in which they arise but the tax so charged shall not exceed: a) 5 percent of the gross amount of such payments if they are made as consideration for the use of, or the right to use, any copyrigh of literary, artistic or scientific work; b) 15 percent of the gross amount of such payments if they are made as consideration for the use of, or the right to use, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience, of for the use of, or the right to use, cinematograph films or tapes for television or broadcasting. 3. The competent authorities of the States shall settle the mode of application of pargraph 2. 4. The provisions of paragraphs 1 and 2 shall not apply if the recipient of the royalties, being a resident of one of the States, has in the other State in which the royalties arise a permanent establishment with which the right or property giving rise to the royalties is effectively connected. In such a case, the provisions of Article 7 shall apply, provided that under law of that other State the royalties are taxed as part of the profits of that permanent establishment. 5. Royalties 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 royalties, whether, he is a resident of one of the States or not, has is one of the States a permanent establishment in connection with which the contract under which the royalties are paid was concluded, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment is situated. 6. Where, owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties paid, having regrad to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisons of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each State; due regard being had to the other provisions of this Convention. ARTICLE 13
LIMITATION OF ARTICLES 10, 11 AND 12 International organizations, organs and officials thereof and members of a diplomatic or consular mission of a third State, being present in one of the States, are not entitled, in the other State, to the reductions or exemptions from tax provided for in Article 10, 11 and 12 in respect of the items of income dealt with in these Articles and arising in that other State, if such items of income are not subject to a tax on income in the first-mentioned State. ARTICLE 14
CAPITAL GAINS 1. Gains from the alienation of immovable property, as defined in paragraph 2 of Article 6, may be taxed in the state in which such property is situated. 2. Gains from the alienation of movable property, forming part of the business property of a permanent establishment which an enterprise of one of the States has in the other State, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise), may be taxed in the other State. 3. Notwithstanding the provisions of paragraph 2, gains from the alienation of ships and aircraft operated in international traffic, and movable property pertaining to the operation of such ships and aircraft shall be taxable only in the State in which the place of effective management of the enterprise is situated. 4. Gains from the alienation of any property other than those mentioned in paragraphs 1, 2 and 3, shall be taxable only in the State of which the alienator is a resident. 5. The provisions of paragraph 4 shall not affect the right of each of the States to levy according to its own law a tax on gains from the alienation of shares or &qupercent;jouissance&qupercent; rights in a company, the capital of which is sholly or partly divided into shares and which is a resident of that State, derived by an individual who is a resident of the percenther State and has been a resident of the first-mentioned State in the course of the last five years preceding the alienation of the shares or &qupercent;jouissance&qupercent; rights. ARTICLE 15
PERSONAL SERVICES 1. Subject to the provisions of Article 16, 18, 19, 20, and 21, remuneration derived by a resident of one of the States in respect of personal services (including the practice of a liberal profession) shall be taxable only in that State unless the services are rendered in the percenther State. If the services are so rendered, such remuneration as is derived therefrom may be taxed in that percenther State. 2. Npercentwithstanding the provisions of paragraph 1, remuneration derived by a resident of one of the States in respect of such services rendered in the percenther State shall be taxable only in the first-mentioned State if: a) the recipient is present in the percenther State for a period or periods npercent exceeding in the aggregate 183 days in the fiscal year concerned, and b) the remuneration is paid by, or on behalf of, a person who is npercent a resident of the percenther State, and c) the remuneration is npercent borne by a permanent establishment which the person paying the remuneration has in the percenther State. 3. Notwithstanding the preceding provisions of this Article, remuneration is respect of an employment exercised aboard a ship or aircraft in international traffic, many be taxed in the State in which the place of effective management of enterprise is situated. | 
