TMI BlogInterestX X X X Extracts X X X X X X X X Extracts X X X X ..... nt of the other Contracting State, the tax so charged shall not exceed : (a) 10 per cent of the gross amount of the interest if such interest is paid on a loan granted by a bank carrying on a bona fide banking business or by a similar financial institution (including an insurance company) ; and (b) 15 per cent of the gross amount of the interest in all other cases. 3. Notwithstanding the pro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at State, and derived and beneficially owned by any person, other than a person referred to in sub-paragraphs (a) and (b), who is a resident of the other Contracting State, provided that the transaction giving rise to the debt-claim has been approved in this behalf by the Government of the first-mentioned Contracting State ; shall be exempt from tax in the first-mentioned Contracting State. 4. T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the interest is attributable to such permanent establishment or fixed base. In such case the provisions of Article 7 (Business Profits) or Article 15 (Independent Personal Services), as the case may be, shall apply. 6. Interest shall be deemed to arise in a C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of the Convention. - - statute, statutory provisions legislation, law, enactment, Acts, Rules, Regulatio ..... X X X X Extracts X X X X X X X X Extracts X X X X
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