Interest taxation under the treaty limits source-state withholding, provides exemptions, and governs PE attribution rules. Article 11 permits residence-state taxation of interest paid to its residents while allowing source-state taxation limited by treaty caps for beneficial ... Summary
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Interest taxation under the treaty limits source-state withholding, provides exemptions, and governs PE attribution rules.
Article 11 permits residence-state taxation of interest paid to its residents while allowing source-state taxation limited by treaty caps for beneficial owners, provides exemptions for specified public institutions and approved transactions, defines interest as income from debt-claims with stated exclusions, attributes interest to permanent establishments or fixed bases for taxation under business profits or independent personal services, and applies arm's-length adjustment where related-party relationships inflate interest amounts.
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TaxTMI 
TaxTMI 
