Interest
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....ot exceed : (a) 10 per cent of the gross amount of the interest if it is received by any financial institution (including an insurance company); (b) in all other cases, 25 per cent of the gross amount of the 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 recipient of the interest is the gove....
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....provisions of paragraphs 1 and 2 shall not apply if the recipient of the interest, being a resident of a Contracting State, carries on business in the other Contracting 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 in....