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TMI BlogInterestX X X X Extracts X X X X X X X X Extracts X X X X ..... ner 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: (a) interest arising in a Contracting State shall be exempt from tax in that Contracting State provided it is derived and beneficially owned by: (i) the Government, a political sub-division or local authority of the other Contracting State; ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ublic financing of external trade. 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 and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ontracting State itself, a political subdivision, a local authority or a resident of that Contracting 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 by su ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Substituted vide Notification No. 650(E) dated 10-07-2000 w.e.f. 01-04-1995 2 . Substituted vide Notification No. 650(E) dated 10-07-2000 w.e.f. 01-04-1997 before it was read as, 1 [ 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 recipient is the beneficial owner of the interest, the tax so charged shal ..... X X X X Extracts X X X X X X X X Extracts X X X X
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