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(9) Any provision in the law of either Contracting State relating only to interest paid to a non-resident company shall not operate so as to require such interest paid to a company which is a resident of the other Contracting State to be treated as a distribution or dividend by the company paying such interest. The preceding sentence shall not apply to interest paid to a company which is a resident of one of the Contracting States if more than 50 per cent of the voting power in the company receiving the interest is controlled, directly or indirectly, by a person or persons who are residents of the other Contracting State.
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