Article 11Income from Debt-Claims
(1) Income from debt-claims arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State.
(2) However, income from debt-claims arising in a Contracting State may also be taxed in that Contracting State and according to the laws of that Contracting State, but if the beneficial owner of that income is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of that income.
(3) Notwithstanding the provisions of paragraph 2 of this Article, income from debt-claims arising in a Contracting State shall be exempt from tax in that Contracting State provided it is derived and beneficially owned by:
a) in the case of the Slovak Republic:
(i) the Government of the Slovak Republic,
(ii) the local authorities,
(iii) Národná banka Slovenska (the National Bank of Slovakia),
(iv) Eximbanka SR (Export-Import Bank of the Slovak Republic),
(v) Slovenská záručná a rozvojová banka, a. s. (Slovak Guarantee and Development Bank),
(vi) Agentúra pre riadenie dlhu a likvidity (Debt and Liquidity Management Agency),
(vii) such other similar institution the capital of which is wholly owned by the Government of the Slovak Republic or local authorities as may be agreed upon from time to time between the Contracting States through an exchange of diplomatic notes.
b) in the case of the Kingdom of Saudi Arabia:
(i) the Government of the Kingdom of Saudi Arabia;
(ii) the Saudi Arabia Monetary Agency (SAMA);
(iii) the Saudi Fund for Development;
(iv) the Public Investment Fund;
(v) the Public Pension Agency;
(vi) the General Organization for Social Insurance; and
(vii) such other similar institution the capital of which is wholly owned by the Government of the Kingdom of Saudi Arabia as may be agreed upon from time to time between the Contracting States through an exchange of diplomatic notes.
(4) The term “income from debt-claims” 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 income from debt-claims for the purpose of this Article.