Common use of Income from Debt-Claims Clause in Contracts

Income from Debt-Claims. 1. Income from debt-claims arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such income from debt-claims may also be taxed in the Contracting State in which it arises and according to the laws of that Contracting State, but if the beneficial owner of the income from debt-claims is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the income from debt-claims. 3. Notwithstanding the provisions of paragraph 2 of this Article, income from debt-claims arising in a Contracting State shall be taxable only in the other Contracting State if: (a) the income from debt-claims is beneficially owned by the Government of that other Contracting State, a political subdivision or local authority thereof, or the central bank of that other Contracting State or any institution wholly owned by that Government; or (b) the income from debt-claims is beneficially owned by a resident of that other Contracting State with respect to debt-claims guaranteed, insured or indirectly financed by the Government of that other Contracting State, a political subdivision or local authority thereof, or the central bank of that other Contracting State or any institution wholly owned by that Government.

Income from Debt-Claims. 1. Income from debt-claims arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such income from debt-claims may also be taxed in the Contracting State in which it arises and according to the laws of that Contracting State, but if the beneficial owner of the income from debt-claims is a resident of the other Contracting State, the tax so charged shall not exceed 10 5 per cent of the gross amount of the income from debt-claims. 3. Notwithstanding the provisions of paragraph 2 of this Article, income from debt-claims arising in a Contracting State shall be taxable only in the other Contracting State if: (a) the income from debt-claims is beneficially owned by the Government of that other Contracting State, a political an administrative subdivision or local authority thereof, or the central bank of that other Contracting State or any institution wholly owned by that Government; or (b) the income from debt-claims is beneficially owned by a resident of that other Contracting State with respect to debt-claims guaranteed, insured or indirectly financed by the Government of that other Contracting State, a political an administrative subdivision or local authority thereof, or the central bank of that other Contracting State or any institution wholly owned by that Government.

Income from Debt-Claims. 1. Income from debt-claims arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, such "income from debt-claims claims" may also be taxed in the Contracting State in which it arises and according to the laws of that Contracting State, but if the beneficial owner of the income from debt-claims is a resident of the other Contracting State, the tax so charged shall not exceed 10 5 per cent of the gross amount of the income from debt-claims. 3. Notwithstanding the provisions of paragraph 2 of this Article, income from debt-claims arising in a Contracting State and paid to a resident of the other Contracting State who is the beneficial owner thereof shall be taxable only in that other State to the other Contracting State if: (a) the extent that such income from debt-claims is beneficially owned by paid: a) to the Government of the other Contracting State including its administrative subdivisions or local authorities; b) to the Central Bank of that other State; c) to a pension scheme of that other Contracting State; d) with respect to in indebtedness arising as a consequence of the sale on credit of any equipment, a political subdivision or local authority thereofmerchandise, or the central bank services; e) on any loan of that other Contracting State or any institution wholly owned whatever kind granted by that Governmenta financial institution; or (bf) the income from debt-claims is beneficially owned by a resident of that other Contracting State with respect to debt-claims guaranteed, insured or indirectly financed by the Government of that other Contracting State, a political subdivision or local authority thereof, or the central bank of that other Contracting State or any institution wholly owned by that Governmenton loans between companies.