Interest

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....f the other Contracting State in respect of loans or debts shall not exceed 15 per cent of the gross amount of such interest. 3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting State shall be exempt from tax in that State, if :- (a) the payer of the interest is the Government of that Contracting State or a local authority thereof, or (b)&n....

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....forms in that other State independent personal services from a fixed 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 a case, the interest shall be taxable in that other Contracting State according to its own law. 6. Interest shall be deemed to arise in a Contracting State when th....