https://www.taxtmi.com/acts?id=5300 Article 11 limits source taxation of interest paid to a resident beneficial owner by capping withholding tax, provides a lower cap for resident banks, exempts interest beneficially owned by governments and central banks, defines interest to include income from debt-claims, excludes late-payment penalties, disapplies the withholding limitation where interest is effectively connected to a permanent establishment or fixed base (deferring to business or independent services rules), and requires arm's-length adjustment where related-party relationships inflate interest. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 06 Mar 2009 12:13:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5300 Article 11 limits source taxation of interest paid to a resident beneficial owner by capping withholding tax, provides a lower cap for resident banks, exempts interest beneficially owned by governments and central banks, defines interest to include income from debt-claims, excludes late-payment penalties, disapplies the withholding limitation where interest is effectively connected to a permanent establishment or fixed base (deferring to business or independent services rules), and requires arm's-length adjustment where related-party relationships inflate interest. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5300