第4條
Notwithstanding paragraph 2, interest shall be exempted from tax by the Contracting Party where it arises if the interest is beneficially owned by a resident of the other Contracting Party that is a financial institution that is unrelated to and dealing wholly independently with the payer. For the purposes of this Article, the term “financial institution” means a bank or other enterprise substantially deriving its profits by raising debt finance in the financial markets or by taking deposits at interest and using those funds in carrying on a business of providing finance.