Interest

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..... he interest the tax so charged shall not exceed 1 [ 10 per cent ] of the gross amount of the interest. 3. Notwithstanding the provisions of paragraph 2, (a) interest arising in a Contracting State shall be exempt from tax in that State, provided it is derived and beneficially owned by: (i) the Government, a political sub-division or a local authority of the other Contracting State; or (ii) the Cen .....

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..... uding premiums and prizes attaching to such securities, bonds or debentures. Penalty charges for late payment shall not be regarded as interest for the purpose of this Article. 5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the interest, being a resident of a Contracting State carries on business in the other Contracting State in which the interest arises, throu .....

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..... such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 7. Where, by reason of a special relationship between payer and the beneficial owner or between both of them and some other person, the amount of interest, having regard to the debt-claim for whic .....

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