Interest
X X X X Extracts X X X X
X X X X Extracts X X X X
....erest is a resident of the other Contracting State, 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 Contracting State shall be exempt from tax in that State provided it is derived and beneficially owned by: (a) in the case of Malaysia: (i) the Government of Malaysia; ....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... (vi) the Reserve Bank of India; (vii) the Industrial Finance Corporation of India; (viii) the Industrial Development Bank of India; (ix) the National Housing Bank; and (x) the Small Industrial Development Bank of India; (c) any other institution as may be agreed from time to time between the competent authorities of the Contracting States. 4. The t....
X X X X Extracts X X X X
X X X X Extracts X X X X
....vices from a fixed base situated therein, and the debt claim in respect of which the interest is paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 6. Interest shall be deemed to arise in a Contracting State when the payer is a resident of that State. Where, however, the person ....
Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
TaxTMI