https://www.taxtmi.com/acts?id=4652 Article 12 permits residence-state taxation of interest and allows source-state taxation subject to a capped charge; it provides institutional exemptions for interest paid to certain public financial bodies and exempts interest on loans guaranteed by those bodies. Interest is broadly defined as income from debt-claims and is deemed to arise where the payer or the payer's permanent establishment or fixed base bearing the indebtedness is situated. Nexus and anti-abuse rules require application of business profits or independent personal services provisions where the interest is effectively connected to a permanent establishment or fixed base, and treaty relief is limited to arm's-length interest where special relationships inflate payments. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 06 Mar 2009 16:17:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4652 Article 12 permits residence-state taxation of interest and allows source-state taxation subject to a capped charge; it provides institutional exemptions for interest paid to certain public financial bodies and exempts interest on loans guaranteed by those bodies. Interest is broadly defined as income from debt-claims and is deemed to arise where the payer or the payer's permanent establishment or fixed base bearing the indebtedness is situated. Nexus and anti-abuse rules require application of business profits or independent personal services provisions where the interest is effectively connected to a permanent establishment or fixed base, and treaty relief is limited to arm's-length interest where special relationships inflate payments. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4652