TMI BlogINTERESTX X X X Extracts X X X X X X X X Extracts X X X X ..... of the other territory, 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 territory shall be exempt from tax in that territory, provided that it is derived and beneficially owned by: ( a ) the authority administering a territory, a sub-division or a local authority of the other terri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s Article. 5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the interest, being a resident of a territory, carries on business in the other territory in which the interest arises, through a permanent establishment situated therein, or performs in that other territory independent personal services from a fixed base situated therein, and the debt-claims in respe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the payer and the beneficial owner or between both of them and some other person, the amount of the interest, 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 such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part ..... X X X X Extracts X X X X X X X X Extracts X X X X
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