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Interest

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.... beneficial owner of the interest, 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 a Contracting State shall be exempt from tax in that Contracting State provided it is derived and beneficially owned by: (i) the Government, a political sub-division or local aut....

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....t Bank of India; (iii) any institution of the other Contracting State in charge of the public financing of external trade. 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 participate in the debtor's profits, and in particular, income from Government securities and i....

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....may be, shall apply. 6. Interest shall be deemed to arise in a Contracting State when the payer is that Contracting State itself, a political subdivision, a local authority or a resident of that Contracting 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 connect....

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....h Contracting State, due regard being had to the other provisions of this Convention.     ************** NOTES:- 1.  Substituted vide Notification No. 650(E) dated 10-07-2000 w.e.f. 01-04-1995  2.  Substituted vide Notification No. 650(E) dated 10-07-2000 w.e.f. 01-04-1997 before it was read as, "^1[2. However, such ....