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TMI BlogArticle 11 - InterestX X X X Extracts X X X X X X X X Extracts X X X X ..... ing State may also be taxed in that State according to the laws of that State, if the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not exceed 10% of the gross amount of the interest . The UN Model Tax Convention leaves this percentage to be established through bilateral negotiations. The competent authorities o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... wner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence 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 remai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nterest means Income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor s profits, and income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures. Exclude - Penalty charges for late payment sha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aim in respect of which the interest is paid is effectively connected with (a) such permanent establishment or fixed base, or with (b) business activities referred to in (c) of paragraph 1 of Article 7. In such cases the provisions of Article 7 or Article 14, as the case may be, shall apply. [ Para 4 of Article 11 ] Interest Deemed to be arise in Contrac ..... X X X X Extracts X X X X X X X X Extracts X X X X
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