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436
ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ
1984
(C)
Α
bank or other financial institution; or
(d)
Α
reaident of
a
Contracting State with respect
to debt obligations arising in connection with the
sa1e of property or the performance of
serνices;
sha11 be exempt from tax by the other Contraating State.
(4)
Paragraphs
(2) and
(3)
shall not apply if the recipient
of the interest, being
a
resident of
a
Contraating State,
has a
permanent establishment in the other Oontracting State
and the indebtedness giving rise to the interest i8
effectively connected with such permanent establishment.
Ιη
such a case, the provisions
ο!
Article
8
(Business
Frofits) shall apply.
(5)
Where
any
interest paid by a person to
any
related
person (within the meaning of Article 11 (Related Persons»)
exceeds
Βη
amount which would have been paid to
an
unrelated
person, the provisions of th_is Article sha11 app1y only to
θΟ
much of the interest
Βθ
would have been paid to
an
unrelated person.
Ιη
such a
CΒθθ
the
θΧCθθΒ
payment may be
taxed by each Contracting State according to its
ον/η
1aw,
/
-
including the provisions of this Convention where applicable.
(6)
The term "interest"
Βθ
used in this Convention means
income from bonds, debentures, government securities, notes,
or other evidences
ο!
indebtedness, whether or not secured
and whether or not carrying
a
right to participate
ίη
profits, and debt-claims of every kind,
ΒΒ
well
8Β
a11 other
income which, under the taxation 1aw
ο!
the Contracting
State in which the income has its source,
ίβ
assimi1ated
to income from money lent.
(7)
Interest paid by
a
resident of a Contracting State
to a person other than a resident
ο!
the other Contracting
State shall be exempt from tax by the other Contracting
5tate, unless:
(a)
Suoh interest is treated as income from Bources
within the oiher Contracting 5tate under paragraph
(2)
of Article
6
(Source of Income);
(b) The recipient of the interest has a permanent
establishment
1η
the
other Oontracting State
and
the
iηdebtedness
giving rise to the interest
fs
effectively oonnected
with
8uch permanent
establishment;
or