Interest

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..... ged shall not exceed 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 local authority thereof, the Central Bank of that other Contracting State or any agency wholly owned by that Government or local authority shall be exempt from tax of the first-menti .....

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..... lishment 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 16, as the case may be, shall apply. 6. Interest shall be deemed to arise in a Contracti .....

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..... een 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 ContractingState, due regard being had to the other provisions of this Agreement. - - statute, statutory provisions legislation, law, enactm .....

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