Interest

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..... rest, the tax so charged shall not exceed 10 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, a political sub-division or a local authority of the other Contracting State; or (b) such agency or instrumentality of the Government of the other Contracti .....

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..... a permanent establishment situated therein, or performs in that other 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 with such permanent establishment or fixed base. In such case, the provisions of article 7 or 15, as the case may be, shall apply. 6. Interest shall be deemed to arise in a .....

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..... 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 apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention. - - .....

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