Interest

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..... t of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the interest. 3. Notwithstanding the provisions of paragraph 2, (a) interest arising in India shall be taxable only in Finland if the interest is paid to: (i) the State of Finland, or a local authority or a statutory body thereof; (ii) the Finnish Fund for Industrial Co-operation (FINNFUND), Fi .....

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..... o in sub-paragraph (a) or sub-paragraph (b) and paid to a resident of the other Contracting State shall be taxable only in that other State. 4. The term interest as used in this Article 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 in particular, income from Government securities a .....

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..... l apply. 6. Interest shall be deemed to arise in a Contracting State when the payer is 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 b .....

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