https://www.taxtmi.com/acts?id=4194 The Agreement permits taxation of interest by the beneficiary's resident State while allowing the source State to tax such interest under its law, limited by a withholding cap on gross interest. Interest includes government securities, bonds, debentures and other indebtedness; exclusions elsewhere in the Agreement apply. If the beneficial owner has a permanent establishment or fixed base and the indebtedness is effectively connected, taxation follows business profits or independent services rules. Interest is sourced to the payer or the payer's permanent establishment when the indebtedness is borne there. Special-relationship adjustments restrict treaty relief to an arm's-length interest amount, with excess taxable under domestic law. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 25 Nov 2024 15:01:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4194 The Agreement permits taxation of interest by the beneficiary's resident State while allowing the source State to tax such interest under its law, limited by a withholding cap on gross interest. Interest includes government securities, bonds, debentures and other indebtedness; exclusions elsewhere in the Agreement apply. If the beneficial owner has a permanent establishment or fixed base and the indebtedness is effectively connected, taxation follows business profits or independent services rules. Interest is sourced to the payer or the payer's permanent establishment when the indebtedness is borne there. Special-relationship adjustments restrict treaty relief to an arm's-length interest amount, with excess taxable under domestic law. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4194