https://www.taxtmi.com/acts?id=4940 Article 11 limits source-state taxation of cross-border interest where the recipient is the beneficial owner, sets a maximum charge by the source State, and exempts interest taxable solely in the recipient State when derived or beneficially owned by governments, central banks or designated government-owned financial institutions or by residents with government-guaranteed or indirectly financed debt-claims. Interest is broadly defined as income from debt-claims; taxation is displaced where the beneficial owner's interest is effectively connected with a permanent establishment or fixed base, in which case provisions for business profits or independent personal services apply. en-us Sat, 19 Jan 2008 22:45:54 +0530 Sat, 07 Dec 2024 10:48:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4940 Article 11 limits source-state taxation of cross-border interest where the recipient is the beneficial owner, sets a maximum charge by the source State, and exempts interest taxable solely in the recipient State when derived or beneficially owned by governments, central banks or designated government-owned financial institutions or by residents with government-guaranteed or indirectly financed debt-claims. Interest is broadly defined as income from debt-claims; taxation is displaced where the beneficial owner's interest is effectively connected with a permanent establishment or fixed base, in which case provisions for business profits or independent personal services apply. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4940