Interest

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..... e, guaranteed or insured, or a credit extended, guaranteed or insured by the Government, a political subdivision, a statutory body or a local authority of India or the Export-Import Bank of India, the Reserve Bank of India, the Industrial Finance Corporation of India, the Industrial Development Bank of India, the National Housing Bank, the Small Industries Development Bank of India or by any institution specified and agreed in letters exchanged between the competent authorities of the Contracting States. ] (b) interest arising in India and paid to a resident of Switzerland shall be taxable only in Switzerland if it is paid in respect of a loan made, guaranteed or insured, or a credit extended, guaranteed or insured under the Swiss provision .....

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..... through 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 a case the provisions of Article 7 or Article 14, as the case may be, shall apply. 6. Interest shall be deemed to arise in a Contracting State when the payer is that 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 or a fixed base in connection with which the ind .....

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..... per cent of the capital of the company paying the interest which are a resident of the other Contracting State and are the beneficial owner of the interest the tax so charged in the Contracting State in which the interest arises shall not exceed 10 per cent of the gross amount of the interest. 3. Re-Numbered vide Notification No. 35 dated 07-02-2001 before it was read as, 4. 4. Substituted vide Notification No. 35 dated 07-02-2001 before it was read as, 3 [ 3. ] Notwithstanding the previsions paragraph 2 and 3. (a) interest arising in Switzerland and paid to a resident of India shall be taxable only in India if it is paid in respect of a loan made, guaranteed or insured, or a credit extended, guaranteed or insured by the Export-Import Bank .....

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