ARTICLE 11 Interest 　　1. Interest arising in a Contracting State and derived by 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 percent of the gross amount thereof. 　　3. Notwithstanding the provisions of paragraph 2: 　　a) interest beneficially owned or paid by a Contracting State, subdivision or local authority thereof, and such government instrumentalities as may be agreed upon by the competent authorities, shall be taxable only in that State; 　　b) interest arising in a Contracting State and paid to a resident of the other Contracting State in respect of a loan for a period of not less than three years made, guaranteed, or insured by any export credit agency wholly owned by that other Contracting State shall only be taxable in that other State. 　　4. 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 or has carried on business in the other Contracting State through a permanent establishment situated therein, or performs or has performed in that other State independent personal services from a fixed base situated Therein, and the interest is attributable to such permanent establishment or fixed base. In such case The provisions of Article 6 (Business profits) or Article 14 (Independent Personal Services), as the case may be, shall apply. 　　5. Interest shall be deemed to arise in a Contracting State 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 a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base or derives profits that are taxable on a net basis in that State under paragraph A of Article 9 (Income from Real Property), paragraphs 2 and 3(b) of Article 12 (Royalties), or paragraph 1 or 2 of Article 13 (Gains), and such interest is borne by such permanent establishment or trade or business subject to tax on a net basis, then such interest shall be deemed to arise in the State in which the permanent establishment or trade or business is situated. 　　6. 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 debtclaim 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 the Convention. 　　7. A resident of a Contracting State may be subject in the other Contracting State to a tax, in respect of interest, in addition to the tax on business profits allowable under the other provisions of this Convention. Such additional tax, however, may not exceed 10 percent of the "excess interest amount." 　　　　　　　　　　　　　　　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 is a resident of the other Contracting State, the tax so charged shall not exceed 10 percent of the gross amount of The royalties. In the case of royalties described in subparagraph b) of paragraph 3, the beneficial owner 'lay elect to compute the tax on such income on a net basis as if such income were attributable to a permanent establishment or fixed base in the Contracting State in which the royalties arise. 　　3. The term "royalties" as used in This Convention means: 　　a) 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 computer programs, video cassettes, and cinematograph films and tapes for radio and television broadcasting, any patent, trademark, design or model, plan, secret formula or process, or other like right or property, or for information concerning industrial, commercial, or scientific experience; and 　　b) payments for the use of, or the right to use, industrial, commercial, or scientific equipment. 　　4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on or has carried on business in the other Contracting State through a permanent establishment situated therein, or performs or has performed in that other State independent personal services from a fixed base situated therein, and the royalties are attributable to such permanent establishment or fixed base. In such case the provisions of Article 6 (Business profits) or Article 14 (Independent Personal Services), as the case may be, shall apply. 　　5. Royalties shall be deemed to arise in a Contracting State when paid for the use of or the right to use the right or property in that State. 　　6. 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 royalties, having regard 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 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 the Convention. ARTICLE 13 Gains 　　1. Gains derived by a resident of a Contracting State from the alienation of real property referred to in Article 9 (Income from Real Property) and situated in the other Contracting State may be taxed in that other State. 　　2. Gains from the alienation of 　　a) stock, participations or other rights in the capital of a company or other legal person (whether or not a resident of a Contracting State) the property of which Consists principally of real property situated in a Contracting State; or 　　b) an interest in a partnership, trust, or estate (whether or not a resident of a Contracting State) to the extent attributable to real property situated in a Contracting State may be taxed in that State. For the purposes of this paragraph, the term "real property" includes the shares of a company referred to in subparagraph (a) or an interest in a partnership, trust, or estate referred to in subparagraph (b), and in case of The United States includes a United States real property interest, as defined in section 897 of The Internal Revenue Code (or any successor Statute). 　　3. In addition to gains from the alienation of shares described in paragraph 2 of this Article, gains derived by a resident of a Contracting State from the alienation of stock, participations, or other rights in the capital of a company or other legal person which is a resident of the other Contracting State may be taxed in that other Contracting State if the recipient of the gain, at any time during the 12-month period preceding such alienation, had a participation, directly or indirectly, of at least 25 percent of the vote or value of that company or other legal person. Such gains shall be deemed to arise in that other State to the extent necessary to avoid double taxation. 　　4. Gains from the alienation of personal property which are attributable to a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or which are attributable to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, and gains from the alienation of such permanent establishment (alone or with the whole enterprise) or such fixed base, may be taxed in that other State. 　　5. Gains derived by a resident enterprise of a Contracting State from the alienation of ships, aircraft, or containers operated in international traffic shall be taxable only in that State. 　　6. Gains from the alienation of any property other than property referred to in paragraphs 1 through 5 shall be taxable only in the Contracting State of which the alienator is a resident. ARTICLE 14 Independent Personal Services 　　1. Income derived by an individual who is a resident of a Contracting State from the performance of independent personal services shall be taxable only in that State, unless 　　a) such services are performed or were performed in the other Contracting State; and either 　　b) The income is attributable to a fixed bass which the individual has or had regularly available to him in that other State, or 　　c) such individual is present or was present in that other State for a period or periods exceeding in the aggregate 183 days in any consecutive twelve-month period. 　　In such a case the income attributable to the services may be taxed in that other State in accordance with principles similar to those of Article 6 (Business Profits) for determining the amount of business profits and attributing business profits to a permanent establishment. 　　2. The term "independent personal services" includes, in particular, independent scientific, literary, artistic, educational or teaching activities, as well as the independent services of physicians, lawyers, engineers, architects, dentists, and accountants. ARTICLE 15 Income from Employment 　　1. Subject to the provisions of Articles 16 (Directors' Fees); 17 (Government Service), and 18 (Pensions, Etc.), salaries, wages, and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 　　2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if 　　a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period; and 　　b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and 　　c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State. 　　3. Remuneration derived by a resident of a Contracting State that would otherwise be taxable in the other Contracting State under the preceding provisions of this Article may be taxed only in the first mentioned State when the remuneration is in respect of employment as a member of the regular complement of a ship or aircraft operated in international traffic. ARTICLE 16 Directors' Fees 　　Directors' fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or similar body of a company which is a resident of the other Contracting State may be taxed in that other State. ARTICLE 17 Government Service 　　1. a) Remuneration, other than a pension, paid from the public funds of a Contracting State, a subdivision or local authority thereof to an individual in respect of services rendered in the discharge of functions of a governmental nature shall be taxable only in that State. 　　b) However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who: 　　i) is a citizen of that State; or 　　ii) did not become a resident of that State solely for the purpose of rendering the services. 　　2. Notwithstanding the provisions of paragraph 1, the provisions of Article 14 (Independent Personal Services) or Article 15 (Income from Employment), as the case may be, shall apply to remuneration paid in respect of services rendered in connection with a business. ARTICLE 18 Pensions, Etc. 　　1. Subject to the provisions of paragraph 2, 　　a) pensions and similar remuneration derived and beneficially owned by a resident of a Contracting State in consideration of past employment may be taxed only in that State; and 　　b) social security benefits and other public pensions paid by a Contracting State may be taxed only in that State. 　　2. a) Any pension paid to an individual in respect of services rendered to a Contracting State, subdivision, or authority in the discharge of functions of a governmental nature and paid by, or out of funds created by, that State, subdivision or local authority shall be taxable only in that Contracting State. 　　b) However, such pension shall be taxable only in the other Contracting State if the individual is a resident of, and a citizen of, that other Contracting State. 　　3. Annuities derived and beneficially owned by an individual who is a resident of a Contracting State shall be taxable only in that State. The term "annuities" as used in this paragraph means a stated sum paid periodically as stated times during a specified number of years, under an obligation to make the payments in return for adequate and full consideration (other than services rendered.) 　　4. Alimony paid to a resident of a Contracting State shall be taxable only in that State. The term "alimony" as used in this paragraph means periodic payments made pursuant to a written separation agreement or a decree of divorce, separate maintenance, or compulsory support, which payments are taxable to the recipient under the laws of the State of which he is a resident. 　　5. Periodic payments for the support of a minor child made pursuant to a written separation agreement or a decree of divorce, separate maintenance, or compulsory support, paid by a resident of a Contracting State to a resident of the other Contracting State shall be taxable only in the first-mentioned State. ARTICLE 19 Students. Trainees and Researchers 　　1. An individual who is a resident of a Contracting State at the beginning of his visit to the other Contracting State and who is temporarily present in that other State for the primary purpose of: 　　a) studying at a university or other accredited educational institution in that other State, or 　　b) securing training required to qualify him to practice a profession or professional specialty, or 　　c) studying or doing research as a recipient of a grant, allowance, or other similar payments from a governmental, religious, charitable, scientific, literary, or educational organization,　shall be exempt from tax by that other State with respect to payments from abroad for the purpose of his maintenance, education, study, research, or training, and with respect to the grant, allowance, or other similar payments. 　　2. The exemption in paragraph 1 shall apply only for such period of time as is ordinarily necessary to complete the study, training or research, except that no exemption for training and/or research shall extend for a period exceeding five years. 　　3. This Article shall not apply to income from research if such research is undertaken not in the public interest but primarily for the private benefit of a specific person or persons.