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 State. 2. However, such income may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the beneficial owner of the income is a resident of the other Contracting State, the tax so charged shall not exceed 5 per cent of the gross amount of the interest. 3. Notwithstanding the provisions of paragraph 2, income from debt-claims arising in a Contracting State and paid to the Government of the other Contracting State shall be exempt from tax in the first-mentioned State. 4. For the purpose of paragraph 3, the term “Government”: (a) in the case of Bahrain, means the Government of the Kingdom of Bahrain and shall include: (i) the Bahrain Monetary Agency or its statutory successor; (ii) the Bahrain Development Bank; (iii) the Housing Bank; (iv) the Government Pension Fund and the General Organisation for Social Insurance (“GOSI”); (v) the Bahrain Economic Development Board; (vi) any local authority or Statutory body thereof ; and (vii) any institution wholly or mainly owned by the Government of the Kingdom of Bahrain as may be agreed from time to time between the competent authorities of the Contracting States. (b) in the case of Singapore, means the Government of Singapore and shall include: (i) the Monetary Authority of Singapore; (ii) the Government of Singapore Investment Corporation Pte Ltd; (iii) a statutory body; and (iv) any institution wholly or mainly owned by the Government of Singapore as may be agreed from time to time between the competent authorities of the Contracting States.
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Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
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 State.
2. However, such income may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the beneficial owner of the income is a resident of the other Contracting State, the tax so charged shall not exceed 5 per cent of the gross amount of the interest.
3. Notwithstanding the provisions of paragraph 2, income from debt-claims arising in a Contracting State and paid to the Government of the other Contracting State shall be exempt from tax in the first-mentioned State.
4. For the purpose of paragraph 3, the term “Government”:
(a) in the case of Bahrain, means the Government of the Kingdom of Bahrain and shall include:
(i) the Bahrain Monetary Agency or its statutory successor;
(ii) the Bahrain Development Bank;
(iii) the Housing Bank;
(iv) the Government Pension Fund and the General Organisation for Social Insurance (“GOSI”);
(v) the Bahrain Economic Development Board;
(vi) any local authority or Statutory body thereof thereof; and
(vii) any institution wholly or mainly owned by the Government of the Kingdom of Bahrain as may be agreed from time to time between the competent authorities of the Contracting States.
(b) in the case of Singapore, means the Government of Singapore and shall include:
(i) the Monetary Authority of Singapore;
(ii) the Government of Singapore Investment Corporation Pte Ltd;
(iii) a statutory body; and
(iv) any institution wholly or mainly owned by the Government of Singapore as may be agreed from time to time between the competent authorities of the Contracting States.
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Samples: Double Taxation Agreement