Greece - Interest

Article 11. Interest 

1. Interest arising in one of the States and paid to a resident of the other State may be taxed in that other State.

2. However, such interest may also be taxed in the State in which it arises and according to the laws of that State, but if the recipient
is the beneficial owner of the interest the tax so charged shall not exceed 10 per cent of the gross amount of the interest, provided
that where such interest is paid to a bank or a financial institution the tax so charged shall not exceed 8 per cent of the gross amount
of the interest. The competent authorities of the States shall by mutual agreement settle the mode of application of these limitations.

3. The term “interest” as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage but
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. Penalty charges for late payment
shall not be regarded as interest for the purpose of this Article.

4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the interest, being a resident of one of the States,
carries on business in the other State in which the interest arises, through a permanent establishment situated therein, or performs in
that other State independent personal services from a fixed base situated therein, and the debt-claim in respect of which the interest is
paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 15,
as the case may be, shall apply.

5. Interest shall be deemed to arise in one of the States when the payer is that State itself, a political subdivision, a local authority or
a resident of that State. Where, however, the person paying the interest, whether he is a resident of one of the States or not, has in
one of the States a permanent establishment or a fixed base in connection with which the indebtedness on which the interest is paid
was incurred, and such interest is born by such permanent establishment or fixed base, then such interest shall be deemed to arise in
the State in which the permanent establishment or fixed base is situated.

6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other
person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been
agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only
to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each State,
due regard being had to the other provisions of this Convention.

Protocol:

II. Ad Articles 10, 11 and 12

Applications for the restitution of tax levied contrary to the provisions of Articles 10, 11 and 12 have to be lodged with the competent
authority of the State having levied the tax within a period of three years after the expiration of the calendar year in which the tax has
been levied.