Interest withholding tax limitation may cap source taxation when the recipient is the beneficial owner under DTAA framework.

Interest paid to a resident may be taxed by the recipient's state, and may also be taxed in the state where it arises, but if the recipient is the beneficial owner a limitation applies to source taxation and the competent authorities shall settle its application. Interest paid to the government or central bank of the other state is exempt. Where the beneficial owner carries on business or services in the source state through a permanent establishment or fixed base and the debt-claim is effectively connected with that presence, provisions for business or independent services apply.

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