TMI BlogInterestX X X X Extracts X X X X X X X X Extracts X X X X ..... e interest the tax so charged shall not exceed 10 per cent of the gross amount of the interest. 3. Notwithstanding the provisions of paragraphs 1 and 2, interest arising in a contracting State and paid to a resident of the other contracting State shall be taxable only in that other State, if the interest is paid in respect of-- (a) a bond, debenture or other similar obligation of the Governmen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cluding 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 provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the interest, being a resident of a contracting State, carries on business in the other contracting State in which the interest aris ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in the contracting 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 person, the amount of the interest, having regard to the debt ..... X X X X Extracts X X X X X X X X Extracts X X X X
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