Interest

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..... hall not exceed 7.5 per cent of the gross amount of the interest. 3. Notwithstanding the provisions of paragraph 2 interest arising in a Contracting State and paid to the Government of the other Contracting State or a local authority thereof, the Central Bank of that other ContractingState or any agency wholly owned by that Government or local authority shall be exempt from tax in the first-mentio .....

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..... t 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 Article 15, as the case may be, shall apply. 6. Interest shall be deemed to arise in a ContractingState .....

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..... eeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of each Contracting State, due regard being had to the other provisions of this Agreement. 8. For the purposes of th .....

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