Article 2
Article 11 (Interest) of this Convention shall be amended by:
(i) replacing paragraph 2 with the following:
“However, subject to provisions of paragraphs 3, 3A and 4 of this Article, 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 7.5 per cent of the gross amount of the interest,”;
(ii) deleting the paragraph 3(c); and
(iii) inserting a new paragraph 3A as follows:
“Interest arising in a Contracting State shall be exempt from tax in that State provided it is derived and beneficially owned by any bank resident of the other Contracting State carrying on bona fide banking business. However, this exemption shall apply only if such interest arises from debt- claims existing on or before 31st March, 2017.”