Article 11Interest
1. Interest 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, interest arising in a Contracting State may also be taxed in that Contracting State according to the laws of that Contracting 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.
3. Notwithstanding the provisions of paragraph 2 of this Article, interest arising in a Contracting State and derived and beneficially owned by a resident of the other Contracting State shall be exempt from tax in the first-mentioned Contracting State provided the beneficial owner of the interest is dealing wholly independently with the payer and is:
(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),
(b) in the case of New Zealand:
(i) the Government of New Zealand,
(ii) the local authorities,
(iii) the Reserve Bank of New Zealand,
(iv) the New Zealand Export Credit Office.
4. Notwithstanding the provisions of paragraph 3 of this Article, interest referred to in that paragraph may be taxed in the Contracting State in which it arises at a rate not exceeding 10 percent of the gross amount of the interest if the beneficial owner of the interest holds, together with any closely related enterprises, directly or indirectly more than 10 per cent of the voting power in the payer of the interest.
5. 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, as well as all other income treated as income from money lent by the laws, relating to tax, of the Contracting State in which the income arises, but does not include any income which is treated as a dividend under Article 10.
6. The provisions of paragraphs 1, 2, 3 and 4 of this Article shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other