https://www.taxtmi.com/acts?id=5240 The DTAA permits residence-state taxation of interest while allowing source-state taxation subject to a limited withholding tax when the recipient is the beneficial owner. Certain government and specified financial institutions are exempt from source taxation if they beneficially own the interest, and the competent authorities may agree additional exempt institutions. is defined to include income from all debt-claims (excluding penalty charges), is deemed to arise where the payer or the payer's permanent establishment or fixed base is situated, and interest effectively connected with a permanent establishment or fixed base is taxed under the rules for business profits or independent personal services. Special-relationship adjustments limit taxation to an arm's-length amount. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 26 Nov 2024 15:03:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5240 The DTAA permits residence-state taxation of interest while allowing source-state taxation subject to a limited withholding tax when the recipient is the beneficial owner. Certain government and specified financial institutions are exempt from source taxation if they beneficially own the interest, and the competent authorities may agree additional exempt institutions. is defined to include income from all debt-claims (excluding penalty charges), is deemed to arise where the payer or the payer's permanent establishment or fixed base is situated, and interest effectively connected with a permanent establishment or fixed base is taxed under the rules for business profits or independent personal services. Special-relationship adjustments limit taxation to an arm's-length amount. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5240