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TMI BlogInterestX X X X Extracts X X X X X X X X Extracts X X X X ..... rest the tax so charged shall not exceed 10 per cent of the gross amount of the interest. 3. Notwithstanding the provisions of paragraph 2, (a) interest arising in a Contracting State shall be exempt from tax in that State provided it is derived and beneficially owned by : (i) the Government, a political sub-division or a local authority of the other Contracting State; or (ii) the Central Bank of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ebtor'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. 5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the interest, being a res ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ment or a fixed base in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 7. Where by reason of a special relationship between the payer and the beneficial owne ..... X X X X Extracts X X X X X X X X Extracts X X X X
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