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5. Where a company which is a resident of a Contracting State derives profits or income from the other

Contracting State, that other State may not impose any tax on the dividends paid by the company, except insofar

as such dividends are paid to a resident of that other State or insofar as the holding in respect of which the

dividends are paid is effectively connected with a permanent establishment situated in that other State, nor

subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends

paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

ARTICLE 11

INTEREST

1. Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed

in that other State.

2. However, such interest may also be taxed in the Contracting State in which it arises and according to the

laws of that State, but if the beneficial owner of the interest is a resident of the other Contracting State, the tax

so charged shall not exceed 10 per cent of the gross amount of the interest. The competent authorities of the

Contracting States shall by mutual agreement settle the mode of application of this limitation.

3. Notwithstanding the provisions of paragraphs 1 and 2, interest arising in a Contracting State shall be

taxable only in the other Contracting State if the interest is paid by or beneficially owned by a Contracting State,

a political or administrative subdivision or local authority thereof, the central bank of a Contracting State or any

agency or instrumentality wholly owned by any of the foregoing.

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. Penalty charges for late payment shall not be regarded as

interest for the purpose of this Article.

5. The provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the interest, being a

resident of a Contracting State, carries on business in the other Contracting State in which the interest arises

through a permanent establishment situated therein and the debt-claim in respect of which the interest is paid is

effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply.

6. Interest shall be deemed to arise in a Contracting State when the payer is a resident of that State. 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 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, 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 Contracting State, due regard

being had to the other provisions of this Convention.

ARTICLE 12

ROYALTIES

1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be

taxed in that other State.

2. However, such royalties may also be taxed in the Contracting State in which they arise and according to

the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the

tax so charged shall not exceed 5 per cent of the gross amount of the royalties. The competent authorities of the

Contracting States shall by mutual agreement settle the mode of application of this limitation.

3. The term “royalties” as used in this Article means payments of any kind received as a consideration for

the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films,