- 1
- It is understood that the term “a loan of whatever kind” as used in subparagraph c) of paragraph 3 of Article 11 also includes convertible bonds and, as a consequence, the term “interest” as used in paragraph 5 of Article 11 also includes income from non-convertible bonds and income from convertible bonds until such time as the later bonds are actually converted into shares. It is also understood that in any case the term “interest” does not include items of income which are dealt with under Article 10.
- 2
- Paragraph 3 of Article 11 shall also apply to interest paid to and beneficially owned by:
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- a)the Netherlands Development Finance Company (de Nederlandse Financierings-Maatschappij voor Ontwikkelingslanden N.V.) or any legal successor thereof;
- b)Atradius State Business N.V. in respect of loans granted, approved, guaranteed or insured by the Government of the Netherlands;
- c)the Korporacja Ubezpieczeń Kredytów Eksportowych S.A. (KUKE S.A.), Bank Gospodarstwa Krajowego S.A.
