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Malaysia

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the interest is a resident of the other Contracting State, the tax so charged shallnot exceed 10 per cent of the gross amount of the interest. The competentauthorities of the Contracting States shall exchange information on the modeof application of this limitation.3. Notwithstanding the prOVISIOns of paragraph 2, the Government of aContracting State shall be exempt from tax in the other Contracting State inrespect of interest derived from that other State.4. For the purposes of paragraph 3, the term "Government":(a) in the case of <strong>Malaysia</strong> means the Government of <strong>Malaysia</strong> and shall include:(i)(ii)(iii)(iv)(v)the governments ofthe states;the Bank Negara <strong>Malaysia</strong>;the local authorities;the statutory bodies; andthe Export-Import Bank of <strong>Malaysia</strong> Berhad (EXIM Bank).(b) in the case of Lebanon means the Government ofLebanon and shall include:(i)(ii)(iii)the Central Bank of Lebanon (BdL);the local authorities;the statutory bodies.S. The term "interest" as used in this Article means income from debt-claims ofevery kind, whether or not secured by mortgage and whether or not carrying aright to participate in the debtor's profits, and in particular, income fromgovernment securities and income from bonds or debentures, includingpremiums attaching to such securities, bonds or debentures. Penalty chargesfor late payment shall not be regarded as interest for the purpose of thisArticle.6. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner ofthe interest, being a resident of a Contracting State, carries on business in theother Contracting State in which the interest arises, through a permanentestablishment situated therein, or performs in that other State independentpersonal services from a fixed base situated therein, and the debt-claim inrespect of which the interest is paid is effectively connected with suchpermanent establishment or a fixed base. In such case the provisions ofArticle 7 or Article 14, as the case may be, shall apply.7. Interest shall be deemed to arise in a Contracting State when the payer is thatState itself, a political subdivision, a local authority or a statutory bodythereof, or a resident of that State. Where, however, the person paying theinterest, whether he is a resident of a Contracting State or not, has in aContracting State a permanent establishment or a fixed base in connectionwith which the indebtedness on which the interest is paid was incurred, and11

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