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ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ
1984
435
are effectively connected with such
pe~anent
estab1ishment.
Ιη
such a case, the provisione of Article
8
(Business Profits)
ahall apply.
(4)
Dividends paid by a
cοrροratiοn
of a Contracting
State to
a
person other than a resident of the other
Contracting State shall be exempt from tax by the other
Contracting State, unless
(a)
The recipient
ο!
the dividends has a permanent
establishment
ίη
the other Contracting State and the
shares with respect to which the dividends are paid
are effectively connected with such permanent
estab1ishment; or
(b) The corporation paying the dividends i8 a
Cypriot corporation whioh derives
50
peroent or
more of 1ts total gross income from
οηθ
or more
permallent establishmel1ts whioh such oorl:oration
has
ίιι
the United States.
Article
13
INTEREST
(1) Interest derived from sources within a Contracting
State by a resident
ο!
the other Contracting State may be
taxed by both Contracting States.
(2) The rate of tax imIIoeed by a Contracting State
οη
interest, other than interest described
ίη
paragraph 7(0)
ο!
this Article, derived from sources within that Contracting
State by a resident
ο!
the other Contracting State shall not
exceed
10
percent of the gross amount
ο!
such interest.
(3)
Notwithstanding paragraphs (1) and (2), interest
beneficially derived by:
(a)
Α
Contracting State, or an instrumentality of
that Contracting 5tate not subject to tax by that
Contraoting State
οη
its income;
(b)
Α
resident
ο!
a Contracting State with respect
to debt obligations (including
Bnι
related debt
obligations) guaranteed or insured by that Contracting
State or
ΒΔ
instrumentality thereof;