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Article 11 - Agreements - Kazakstan - Article 11 - Article 11 : 1. arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such may also be taxed in the Contracting State in w .....

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ies of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3. Notwithstanding the provisions of paragraph 2, arising in a Contracting State shall be exempt from tax in that State, provided it is derived .....

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may be mutually agreed upon between the two Contracting States. 4. The term "" 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 .....

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ed 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 .....

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or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 6. shall be deemed to arise in a Contracting State when the payer is 1[***] a resident of that State. Where, however, the person paying the , whe .....

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r fixed base, then such shall be deemed to arise in the 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 ot .....

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