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Interest

at other State. 2. However, such may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the recipient and the beneficial owner of the is a resident of other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the . The competent authorities of the Contracting States shall by mutual agreement settle the mod .....

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ng premiums and prizes attaching to the such securities, bonds or debentures. Penalty charges for late payment shall not be regarded as for the purpose of this Article. 5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the , being a resident of a Contracting State, carries on business in the other Contracting State in which the arises, through a permanent establish .....

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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 , 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 pr .....

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