TMI BlogINTERESTX X X X Extracts X X X X X X X X Extracts X X X X ..... 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, any such interest referred to in paragraph 1 shall be taxable only in the Contracting State of which the recipient is a resident, if such resident is the beneficial owner of the interest and if s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are wholly owned and controlled by the Government of India or the Reserve Bank of India. ( c ) to any other institution as may be agreed upon from time to time between the competent authorities of the Contracting States through exchange of letters. 4. The term "interest" as used in this Article means income from debt claims of every kind, whether or not secured by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ebt claim in respect of which the interest is paid is 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 Contracting State when the payer is a resident of that State. Where, however, the person paying the interest, whether he is a reside ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 this Agreement. - - statute, statutory provisions legislation, law, enactment, Acts, Rules, Regulations, Taxation Tax Management India - taxmanagementindia - taxmanagement - taxmanagementindia.com - TMI - TaxTMI - ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
