Interest

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.... the interest is a resident of the other Contracting State the tax so charged shall not exceed: (a) 10 per cent. of the gross amount of the interest, if such interest is paid on any loan of whatever kind granted by a bank; and (b) 15 per cent. of the gross amount of the interest in all other cases. 3. The term "interest" as used in this Article means income from debt-claims of....

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.... 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 14, as the case may be, shall apply. 5. Interest shall be deemed to arise in a Contracting State when the payer is that State itself, a political sub-division, a local author....