Article 2 of the Protocol amends Article 2 (Interest) of the Convention to reduce the rate

of tax at source on interest and to clarify the treatment of interest paid to the Government or a governmental entity of a Contracting State. Paragraph 2 of Article 12 of the Convention is amended to reduce from 15 percent to 10 percent the rate of tax that may be imposed at source on most categories of interest derived from sources within one Contracting State and beneficially owned by a resident of the other Contracting State.