Interest

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....t 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) the Government, a political subdivision or a local authority of the othe....

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....he interest is paid in respect of a loan made, guaranteed or insured or a credit extended, guaranteed or insured by the Government or a local authority of Latvia or by any of the bodies mentioned in sub-paragraph (b) (ii) or (c). 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 p....

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...., 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 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 resi....