https://www.taxtmi.com/acts?id=5066 Interest paid to a resident of the other Contracting State may be taxed in the recipient's State, while the source State may also tax such interest subject to a treaty withholding tax cap where the recipient is the beneficial owner. Interest is exempt in the source State if derived and beneficially owned by the other State's Government, Central Bank, or agreed governmental financial institutions. The Article defines interest broadly, excludes late-payment penalties, treats interest as arising with the payer or a connected permanent establishment, and limits treaty relief where special relationships inflate interest beyond arm's-length amounts. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 25 Nov 2024 16:52:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5066 Interest paid to a resident of the other Contracting State may be taxed in the recipient's State, while the source State may also tax such interest subject to a treaty withholding tax cap where the recipient is the beneficial owner. Interest is exempt in the source State if derived and beneficially owned by the other State's Government, Central Bank, or agreed governmental financial institutions. The Article defines interest broadly, excludes late-payment penalties, treats interest as arising with the payer or a connected permanent establishment, and limits treaty relief where special relationships inflate interest beyond arm's-length amounts. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5066