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May be taxed in both states. Limit for tax in the source state is 10% of the gross amount. Exempt in the source country if derived by central banks, government or political subdivisions. If such interest income is effectively connected with PE, such interest is to be charged as business income

This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.

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