Interest

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..... st the tax so charged shall not exceed: (a) 10 per cent of the gross amount, if such interest is paid on any loan of whatever kind granted by a bank or a financial institution; and (b) 15 per cent of the gross amount in all other cases. 3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting State shall be exempt from tax in that State, provided that it is derived and b .....

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..... ident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent establishment situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment. In such case, the provisions of Article 7 shall apply. 6. Interest shall be deemed to arise in a Contracting State wh .....

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..... bsence 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 Agreement. - - statute, statutory provisions legislation, law, enactment, Acts, Rules, Regulations, Taxation Tax Managemen .....

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