Interest

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..... nterest the tax so charged shall not exceed 1[10 per cent] of the gross amount of the interest. The competent authorities of the Contracting State shall by mutual agreement settle the mode of application of this limitation. 3. Notwithstanding the provisions of paragraph (2), interest arising in a Contracting State shall be exempt from tax in that State provided it is derived and beneficially owne .....

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..... ever, this term does not include income dealt with in article 10. 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 resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a .....

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..... 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 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 .....

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