Interest

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

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.... as interest for the purpose of this Article. 5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the interest, being a resident of a territory, carries on business in the other territory in which the interest arises, through a permanent establishment situated therein, or performs in that other territory independent personal services from a fixed base situated the....