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for a period not exceeding two years, shall not be taxed in that other Contracting State on his remuneration for such teaching or research.

Article XV. A resident of one of the Contracting States who is temporarily present in the other Contracting State solely:

(a) As a student at a recognized university, college or school in such other State,

(b) As a business apprentice, or to acquire technical, professional or business experience, or

(c) As the recipient of a grant, allowance or award for the primary purposes of study or research from a religious, charitable, scientific or recognized educational organization,

shall not be taxed in such other State in respect of remittances from abroad for the purposes of his maintenance, education or training.

Article XVI. 1. Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.

2. However, the Contracting State in which interest arises has the right to tax such interest according to its own law, but the rate of the tax which it charges may not exceed 15 per cent of the amount of the interest. The competent authorities of the two States shall by mutual agreement settle the mode of application of this limitation.

3. 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 in which the income arises.

4. The provisions of the foregoing paragraphs shall not apply where the recipient carries on business in the other Contracting State through a permanent establishment situated therein and such interest is attributable to that permanent establishment; in such event

(a) In Israel article VI of this Convention shall be applicable;

(b) In Italy the laws of Italy shall be applicable.

5. Interest shall be deemed to arise in a Contracting State when the payer is that State itself, or a political sub-division, a local authority or a resident of that State. Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment for the requirements of which the loan on which interest is paid was effected, and such interest is borne by such permanent establishment, then such interest shall be deemed to arise in the Contracting State in which the permanent establishment is situated.

6. Where, owing to a special relationship between the payer 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 payer 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 according to the Contracting States' own laws, due regard being had to the other provisions of this Convention.

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