TMI BlogInterestX X X X Extracts X X X X X X X X Extracts X X X X ..... the beneficial owner of the interest the tax so charged shall not exceed 10 per cent of the gross amount of the interest. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting State shall be exempt from tax in that State provided it is de ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ndustrial Credit and Investment Corporation of India (ICICI); or (iii) any other institution or agency as may be mutually agreed upon between the two Contracting States. 4. The term "interest" 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 debtor's profits, and in particular, inco ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 6. Interest shall be deemed to arise in a ContractingState when the payer is that State itself, a political sub-division, a local authority or a resident of that State. Where, however, the person paying the interest, whether he is a re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ned amount. In such case, the excess part of the payment shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention. - - statute, statutory provisions legislation, law, enactment, Acts, Rules, Regulations, Taxation Tax Management India - taxmanagementindia - taxmanagement - taxmanagementindia.com - TMI - TaxTMI - TMITax ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
