(1) Interest derived from a Contracting State by a
resident of the other Contracting State may be taxed in
that other State.
(2) However, such interest may be taxed in the Con-
tracting State from which it is derived, and according
to the law of that Contracting State, but the tax so
charged shall not exceed:
a) 10 per cent of the gross amount of such interest, if
the recipient is a bank or other financial institution;
b) in all other cases, 20 per cent of the gross amount
of such interest.
(3) Notwithstanding the provisions of paragraph (2),
a) interest derived from the Federal Republic of Germany
and paid to the Liberian Government shall be exempt
from German tax;
bh
interest derived from Liberia and paid to the German
Government, the Deutsche Bundesbank, the Kredit-
anstalt fir Wiederaufbau or to the Deutsche Gesell-
schaft für wirtschaftliche Zusammenarbeit (Entwick-
lungsgesellschaft) shall be exempt from Liberian tax.
The competent authorities of the Contracting States shall
determine by mutual agreement any other governmental
institution to which this paragraph shall apply.
(4) The term "interest" as used in this Article means
income from Government securities, bonds or debentures,
whether or not secured by mortgage and whether or not
carrying a right to participate in profits, and debt-claims
of every kind as well as all other income assimilated to
income from money lent by the taxation law of the
State from which the income is derived.
(5) The provisions of paragraphs (1) and (2) shall not
apply if the recipient of the interest, being a resident of
a Contracting State, has in the other Contracting State
a permanent establishment with which the debt-claim
from which the interest arises is effectively connected.
In such a case, the provisions of Article 7 shall apply.
(6) Interest shall be deemed to be derived from a Con-
tracting State when the payor is that State itself, a Land,
a political subdivision or a local authority thereof or a
resident of that State. Where, however, the person
paying the interest, whether he is a resident of a Con-
tracting State or not, has in a Contracting State a per-
manent establishment in connection with which the
indebtedness on which the interest is paid was incurred,
and such interest is borne by such permanent establish-
ment, then such interest shall be deemed to be derived
from the Contracting State in which the permanent estab-
lishment is situated.
(7) Where, owing to a special relationship between
the payor and the recipient or between both of them
and some other person, the amount of the interest paid,
having regard to the debt-claim for which it is paid,
exceeds the amount which would have been agreed upon
by the payor and the recipient in the absence of such
relationship, the provisions of this Article shall apply
only to the last-mentioned amount. In that case, the
excess part of the payments shall remain taxable ac-
cording to the law of each Contracting State, due regard
being had to the other provisions of this Agreement.