TMI BlogINTERESTX X X X Extracts X X X X X X X X Extracts X X X X ..... , but if the beneficial owner of 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, interest arising in a Contracting State shall be exempt from tax in that State provided it is derived and beneficially owned by: (a) the Government, a political su ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sident of Latvia, if the interest is paid in respect of a loan made, guaranteed or insured or a credit extended, guaranteed or insured by the Government or a local authority of Latvia or by any of the bodies mentioned in sub-paragraph (b) (ii) or (c). 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... base situated therein, and the debt-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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 this Agreement. - - statute, statutory provisions legislation, law, enactment, Acts, Rules, Regulations, Taxation Tax Management India - taxmanagementindia - taxmanagement - taxmanagementindia.com ..... X X X X Extracts X X X X X X X X Extracts X X X X
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