TMI BlogInterestX X X X Extracts X X X X X X X X Extracts X X X X ..... neficial owner of the interest is a resident of the other Contracting State, 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 Switzerland and paid to a resident of India shall be taxable only in India if it is paid in respect of a loan made, guaranteed or insured, or a c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on specified and agreed in letters exchanged between the competent authorities of the Contracting States; 1 [ (c) interest arising in a Contracting State and paid to a resident of the other Contracting State engaged in the operation of ships or aircraft in international traffic shall be taxable only in that other State to the extent that such interest is paid on funds connected with ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pose of this Article. 5. The provisions of paragraphs 1 and 2 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 arises, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e in which the permanent establishment or fixed base is situated. 7. Where, owing to a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest paid, 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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