Interest

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..... arged shall not exceed 10 per cent of the gross amount of the interest. 3. Notwithstanding the provisions of paragraphs 1 and 2, (a) interest arising in India shall be exempt from Indian tax if the interest is paid to (i) the Bank of Finland; and (ii) the Finnish fund for Industrial Cooperation Ltd. (FINNFUND), 1 [ FINNVERA and Finnish Export Credit ] or any other similar institution, as may be ag .....

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..... rnment securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds and 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 recipient of the interest, being a resident of a Contracting State, carries on business in the other .....

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..... 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 State in which the permanent establishment or fixed base is situated. 7. Where, by reason of a special relationship between the payer and the recipient or between both of them and some other person, the amou .....

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