Interest

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....st 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, (a) interest arising in India shall be taxable only in Finland if the interest is paid to: - (i) the State of Finland, or a local authority or a statutory body thereof; (ii) the Finnish ....

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....a Contracting State on a loan guaranteed by any of the bodies mentioned or referred to in sub-paragraph (a) or sub-paragraph (b) and paid to a resident of the other Contracting State shall be taxable only in that other State. 4. The term "interest" as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right to parti....

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.... fixed base. In such case the provisions of Article 7 or Article 14, 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 paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with....