Interest

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.... of the interest the tax so charged shall not exceed 10 per cent of the gross amount of the interest.] 3. Notwithstanding the provisions of paragraph 2, (a) interest arising in a Contracting State shall be exempt from tax in that State provided it is derived and beneficially owned by : (i)  the Government, a political sub-division or a local authority of the oth....

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....sp;any other person provided that the loan or credit is approved by the Government of the first-mentioned Contracting State. 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 carrying a right to participate in the debtor's profits, and in particular, income from Government securities and income f....

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..... 6. Interest shall be deemed to arise in a Contracting State when the payer is that Contracting State itself, a political sub-division, a local authority or a resident of that State. Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtednes....

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.... being had to the other provisions of this Agreement.       ----------------------- NOTES:- 1. Substituted vide Notification No. 47/2014 dated 24 September, 2014 before it was read as, "2. However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the recipient is the beneficial ow....