Interest

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....ner of the interest, the tax so charged shall not exceed 10 per cent of the gross amount of the interest. 3. 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 sub-division or a local authority of the other Contracting State; or (b) such agency or instrumentality of t....

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....g State in which the interest arises, through a permanent establishment situated therein, or performs 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 case, the provisions of article 7 or 15, as the case may be, shall app....