Interest

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.... State, but if the recipient is the beneficial owner 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) of this Article 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 ....

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....tate, carries on business in the other Contracting State in which the interest arises through a permanent establishment situated therein and debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment. In such case, the provisions of Article 7 shall apply. 6. Interest shall be deemed to arise in a Contracting State when the payer is that State ....