https://www.taxtmi.com/acts?id=4910 Article 12 allocates taxing rights over interest, permits source-state taxation subject to a capped withholding, and provides exemptions where the payer is the State or agreed agencies. It broadly defines interest to include government securities and all debt-claims. If the recipient's permanent establishment or fixed base in the source State is effectively connected with the debt-claim, the interest is taxable under the source State's domestic law. Deemed-source rules and related-party arm's-length adjustments govern where interest arises and limit treaty application to amounts consistent with market terms. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 06 Dec 2024 18:23:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4910 Article 12 allocates taxing rights over interest, permits source-state taxation subject to a capped withholding, and provides exemptions where the payer is the State or agreed agencies. It broadly defines interest to include government securities and all debt-claims. If the recipient's permanent establishment or fixed base in the source State is effectively connected with the debt-claim, the interest is taxable under the source State's domestic law. Deemed-source rules and related-party arm's-length adjustments govern where interest arises and limit treaty application to amounts consistent with market terms. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4910