https://www.taxtmi.com/acts?id=4792 The Article permits source-state taxation of interest paid to a resident of the other Contracting State, but limits that tax where the recipient is the beneficial owner to a capped proportion of the gross interest, with competent authorities to determine application. It broadly defines "interest" as income from debt-claims (excluding penalty charges). Exemptions apply when interest is beneficially owned by governments, central banks, specified export-import banks, or other mutually agreed financial institutions. effectively connected to a permanent establishment or fixed base is taxed under business profit or independent services provisions, and related-party excess interest is excluded from the Article and taxed under domestic law. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 21 Nov 2024 12:25:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4792 The Article permits source-state taxation of interest paid to a resident of the other Contracting State, but limits that tax where the recipient is the beneficial owner to a capped proportion of the gross interest, with competent authorities to determine application. It broadly defines "interest" as income from debt-claims (excluding penalty charges). Exemptions apply when interest is beneficially owned by governments, central banks, specified export-import banks, or other mutually agreed financial institutions. effectively connected to a permanent establishment or fixed base is taxed under business profit or independent services provisions, and related-party excess interest is excluded from the Article and taxed under domestic law. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4792