https://www.taxtmi.com/acts?id=4355 Cross-border interest payments may be taxed in the recipient's State and also in the State where the interest arises subject to a treaty withholding cap when the recipient is the beneficial owner. Interest is broadly defined as income from debt-claims, with exemptions for governments, central banks and other approved financial institutions, and further approval-based exemptions for certain resident persons. If the beneficial owner has a permanent establishment or fixed base in the source State and the debt-claim is effectively connected, business profits or independent personal services rules apply. Related-party excess interest is limited to an arm's-length amount. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 17 Oct 2024 10:49:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4355 Cross-border interest payments may be taxed in the recipient's State and also in the State where the interest arises subject to a treaty withholding cap when the recipient is the beneficial owner. Interest is broadly defined as income from debt-claims, with exemptions for governments, central banks and other approved financial institutions, and further approval-based exemptions for certain resident persons. If the beneficial owner has a permanent establishment or fixed base in the source State and the debt-claim is effectively connected, business profits or independent personal services rules apply. Related-party excess interest is limited to an arm's-length amount. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4355