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Interest

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..... s of that State, but if the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not exceed 7.5 per cent of the gross amount of the interest,] 3. Interest arising in a Contracting State shall be exempt from tax in that State provided it is derived and beneficially owned by : (a) the Government or a local authority of the other Contracting State ; .....

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..... to the debt-claim has been approved in this regard by the Government of the first-mentioned Contracting State. 5. The term interest as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage, and whether or not carrying a right to participate in the debtors profits, and, in particular, income from Government securities and income from bonds or debentur .....

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..... ll be deemed to arise in a Contracting State when the payer is that Contracting State itself, 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 in connection with which the indebtedness on which the interest is paid was .....

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..... TES:- 1. Substituted vide NOTIFICATION No. 68/2016 - Dated 10-08-2016 , before it was read as, 2. However, subject to the provisions of paragraphs (3) and (4) of this article, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State. 2. Omitted vide NOTIFICATION No. 68/2016 - Dated 10-08-2016 , before it was read as, (c) any bank carrying .....

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