https://www.taxtmi.com/acts?id=5390 Interest from debt-claims may be taxed in both residence and source States; where the recipient is the beneficial owner and the debt was created after the Convention's entry into force, source tax is capped at a reduced withholding rate. Exemptions apply for interest beneficially owned by a foreign Government or Central Bank and, subject to government approval, for other residents where the debt transaction promotes industrial development. Interest connected to a business via a permanent establishment or fixed base is taxed under business profits or personal services provisions. Special-relationship adjustments limit treaty relief to arm's-length interest. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 06 Mar 2009 17:01:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5390 Interest from debt-claims may be taxed in both residence and source States; where the recipient is the beneficial owner and the debt was created after the Convention's entry into force, source tax is capped at a reduced withholding rate. Exemptions apply for interest beneficially owned by a foreign Government or Central Bank and, subject to government approval, for other residents where the debt transaction promotes industrial development. Interest connected to a business via a permanent establishment or fixed base is taxed under business profits or personal services provisions. Special-relationship adjustments limit treaty relief to arm's-length interest. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5390