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TMI BlogInterestX X X X Extracts X X X X X X X X Extracts X X X X ..... al owner of the interest the tax so charged shall not exceed 10 per cent of the gross amount of the interest. 1 [ 3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting State and paid to the Government, a political subdivision or a local authority, the Central Bank or any financial institution wholly owned by the Government of the other Contracting State, or paid on lo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent establishment situated therein, or performs in that other Contracting 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 w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... se is situated. 7. 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 a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cal authority, and the Central Bank thereof or any financial institution wholly owned by that Government shall be exempt from tax in the first-mentioned Contracting State. - - statute, statutory provisions legislation, law, enactment, Acts, Rules, Regulations, Taxation Tax Management India - taxmanagementindia - taxmanagement - taxmanagementindia.com - TMI - TaxTMI - TMITax - Double Tax Avoidan ..... X X X X Extracts X X X X X X X X Extracts X X X X
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