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TMI BlogInterestX X X X Extracts X X X X X X X X Extracts X X X X ..... of the interest the tax so charged shall not exceed 10 per cent of the gross amount of the interest. 3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting State shall be taxable only in the other Contracting State if: (a) the interest is derived and beneficially owned by the Government of that other Contracting State, a political sub-division or local authority there ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Export and Investment Insurance; and (v) such other financial institution the capital of which is wholly owned by the Government of Japan as may be agreed upon from time to time between the Governments of the Contracting States; (b) in the case of India: (i) Reserve Bank of India; (ii) Export-Import Bank of India; (iii) General Insurance Corporation of India; (iv) New India Assurance Company Limit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rough a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 7. Interest shal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 remain taxable according to the laws of each Contracting State, due re ..... X X X X Extracts X X X X X X X X Extracts X X X X
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