TMI BlogInterest or gainsX X X X Extracts X X X X X X X X Extracts X X X X ..... pient is the beneficial owner of the interest or gains, the tax so charged shall not exceed 10 per cent of the gross amount of the interest or gains. 3. Notwithstanding the provisions of paragraph 2, interest or gains arising in a Contracting State shall be exempt from tax in that State, provided that it is derived and beneficially owned by; (a) the Government, a political sub-division or a l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ght to participate in the debtors profits, and in particular, income from Government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures. Penalty charges for late payment shall not be regarded as interest or gains for the purpose of this Article. 5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a permanent establishment or a fixed base in connection with which the indebtedness on which the interest or gains is paid was incurred, and such interest or gains is borne by such permanent establishment or fixed base, then such interest or gains 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 be ..... X X X X Extracts X X X X X X X X Extracts X X X X
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