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Article 11 - Agreement - DTAA - Article 11 - Article 11 1. arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such may also be taxed in the Contracting State in which it .....

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ph 2, 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-division or a local authority of the other Contracting State; or (b) (i) in the ca .....

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authorities of the Contracting States. ' 4. The term "" as used in this Article means income, from debt-claims of every kind, whether or not secured by mortgage, and whether or not carrying a right to participate in the debtor's pro .....

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aws of the Contracting State in which the income arises. Penalty charges for late payment shall not be regarded as for the purpose of this Article. 5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the , being a resid .....

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and the debt-claim in respect of which the 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. shall be deemed to arise in a Con .....

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