https://www.taxtmi.com/acts?id=5270 Interest arising in a Contracting State may be taxed in the recipient's State, but the source State may also tax such interest subject to a reduced withholding where the recipient is the beneficial owner. Interest is exempt in the source State when beneficially owned by the other State's government, political sub-division, local authority, or agreed agencies. Interest connected with a permanent establishment or fixed base is taxed under business or independent personal services provisions. Interest is sourced to the payer's State or to the State of the payer's PE or fixed base when incurred and borne by that establishment. Special-relationship excesses are limited to arm's-length amounts. en-us Sat, 19 Jan 2008 22:45:54 +0530 Wed, 27 Nov 2024 12:14:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5270 Interest arising in a Contracting State may be taxed in the recipient's State, but the source State may also tax such interest subject to a reduced withholding where the recipient is the beneficial owner. Interest is exempt in the source State when beneficially owned by the other State's government, political sub-division, local authority, or agreed agencies. Interest connected with a permanent establishment or fixed base is taxed under business or independent personal services provisions. Interest is sourced to the payer's State or to the State of the payer's PE or fixed base when incurred and borne by that establishment. Special-relationship excesses are limited to arm's-length amounts. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5270