9911796707
TMI BlogInterestX X X X Extracts X X X X X X X X Extracts X X X X ..... other Contracting State and is the beneficial owner of the interest, the tax charged in the Contracting State in which the interest arises shall not exceed 10 percent of the gross amount of the interest; (b) where the interest is paid to the Government of one of the Contracting States or a political sub-division or local authority of that State or the Reserve Bank of India, it shall not be subject to tax by the State in which it arises. 4. Notwithstanding the provisions of Article 7 of this Convention and of paragraphs 2 and 3 of this Article: (a) interest arising in India which is paid to any beneficially owned by a resident of the United Kingdom shall be exempt from tax in India if it is paid in respect of a loan made, guaranteed or insu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 (Business profits) or Article 15 (Independent personal services) of this Convention, as the case may be shall apply. 7. 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 indebtedness on which the interest is paid was incurred, and such interest is borne by that permanent establishment or fixed base, then suc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tax on such income in the Contracting State of which he is a resident; and (b) sells or makes a contract to sell the holding from which such interest is derived within three months of the date such beneficial owner acquired such holding. 11. The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the debt-claim in respect of which the interest is paid to take advantage of this Article by means of that creation or assignment - - statute, statutory provisions legislation, law, enactment, Acts, Rules, Regulations, Taxation Tax Management India - taxmanagementindia - taxmanagement - taxmanagementindia.com - TMI - TaxTMI - TMITax - Double ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
