11. The zero rate applies to interest paid to any financial institution
wholly owned by the other Contracting State, a "Land", a
political subdivision, a local authority or a local administration
thereof, and in particular, in the case of the Federal Republic, by
the "Deutsche Bundesbank" or the "Kreditanstalt für
Wiederaufbau", and in the case of Thailand, by the "Bank of
Thailand". The 10 percent rate applies to interest paid to a
recipient that is a bank or financial institution (including an
insurance company).