Interest

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..... resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the interest. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 2. However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the benef .....

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..... ng a right to participate in the debtor's profits, and in particular, income from government securities and income from bonds or debentures, including 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 Provision of paragraphs 1 and 2 shall not apply in the beneficial o .....

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..... on with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base; then such interest shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 7. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other pe .....

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