Interest

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....r of the interest the tax so charged shall not exceed: (a) 10 per cent of the gross amount, if such interest is paid on any loan of whatever kind granted by a bank or a financial institution; and (b) 15 per cent of the gross amount in all other cases. 3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting State shall be exempt from tax in....

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....provisions of paragraphs 1 and 2 shall not apply if the beneficial owner 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, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment. In such case, th....