https://www.taxtmi.com/acts?id=4682 Article 12 allocates taxing rights over interest: interest paid to a resident may be taxed in the resident State, and may also be taxed in the source State subject to a withholding ceiling of 10% where the recipient is the beneficial owner. The Article exempts interest beneficially owned by governments, specified central banks and development agencies, and institutions agreed by competent authorities, and exempts interest connected with loans or credits extended or endorsed by certain export or external trade financing agencies. Definitions, deemed-source rules, permanent establishment connection, and a special-relationship arm's-length adjustment are provided. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 19 Nov 2024 16:27:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4682 Article 12 allocates taxing rights over interest: interest paid to a resident may be taxed in the resident State, and may also be taxed in the source State subject to a withholding ceiling of 10% where the recipient is the beneficial owner. The Article exempts interest beneficially owned by governments, specified central banks and development agencies, and institutions agreed by competent authorities, and exempts interest connected with loans or credits extended or endorsed by certain export or external trade financing agencies. Definitions, deemed-source rules, permanent establishment connection, and a special-relationship arm's-length adjustment are provided. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4682