This Article contains provisions relating to the taxation by a Contracting State of the profits of an enterprise of the other Contracting State. It updates the corresponding article of the 1962 Convention to better align with the current policy of the United States Treaty and the OECD model. 5. By reason of a special relationship between the payer and the beneficial owner or between both and another person, taking into account the claim for which it is paid, does the amount of interest exceed the amount agreed by the payer and the beneficial owner in the absence of such a relationship; this Article shall apply only to the latter amount. In that case, the excess part of the payments shall remain taxable under the tax laws of each State, taking due account of the other provisions of this Agreement. Paragraph 1 provides that all income held by a resident Contracting State which is not covered by other articles of the Convention may be taxed only in the State of residence. The scope of this Article shall not be limited to income from one source in the other Contracting State, but shall also apply to income from sources in third countries. In addition, the exclusive right of taxation shall apply whether or not the State of residence withdraws its right to taxation of the income of the State of elimination referred to in the Article. 2. The taxation of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or the remuneration of an individual established in a Contracting State, which is due on a fixed base in the other Contracting State, which is lawfully at the disposal of that resident, may not be levied in that other State less favourably than the taxation of: which is levied by undertakings or residents of that other State carrying out the same activities.

This paragraph shall not be construed as obliging a Contracting State to grant allowances, exemptions and reductions for tax purposes to residents of the other Contracting State by reason of the civil status or family obligations it grants to its own residents. . . .