https://www.taxtmi.com/acts?id=4850 Article 11 allocates taxing rights over interest: interest paid to a resident of the other Contracting State may be taxed in that resident's State, but may also be taxed in the source State where it arises; if the recipient is the beneficial owner the source tax shall not exceed ten percent of the gross interest. Interest connected to a permanent establishment or fixed base is treated as arising in the State where that establishment or base is situated and taxed under business profits or independent personal services provisions. Special-relationship adjustments limit treaty relief to the arm's-length amount. en-us Sat, 19 Jan 2008 22:45:54 +0530 Wed, 04 Dec 2024 17:10:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4850 Article 11 allocates taxing rights over interest: interest paid to a resident of the other Contracting State may be taxed in that resident's State, but may also be taxed in the source State where it arises; if the recipient is the beneficial owner the source tax shall not exceed ten percent of the gross interest. Interest connected to a permanent establishment or fixed base is treated as arising in the State where that establishment or base is situated and taxed under business profits or independent personal services provisions. Special-relationship adjustments limit treaty relief to the arm's-length amount. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4850