TMI BlogINTERESTX X X X Extracts X X X X X X X X Extracts X X X X ..... beneficial owner of the interest is a resident of the other ContractingState, the tax so charged shall not exceed 10 per cent of the gross amount of the interest. 3. Notwithstanding the provisions of paragraph 2, interest 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-divi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... carrying a right to participate in the debtor's 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. 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 ot ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hall be deemed to arise in the State 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 exceeds, for whatever reason, the amount which would have been paid in the absence of such relationship, the provisions of this Art ..... X X X X Extracts X X X X X X X X Extracts X X X X
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