https://www.taxtmi.com/acts?id=5422 Article 12 allocates primary taxation of interest to the recipient's State of residence while permitting source-state taxation at a reduced withholding rate when the recipient is the beneficial owner; exemptions apply for interest beneficially owned by the Government, political sub-divisions, local authorities or the Central Bank, and approved transactions may be exempt by the source State. Interest is defined as income from debt-claims, excludes penalty charges, is deemed to arise with a resident payer or when a permanent establishment or fixed base bears the indebtedness, and payments exceeding arm's-length amounts due to special relationships are limited to the arm's-length amount. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 27 Aug 2024 16:46:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5422 Article 12 allocates primary taxation of interest to the recipient's State of residence while permitting source-state taxation at a reduced withholding rate when the recipient is the beneficial owner; exemptions apply for interest beneficially owned by the Government, political sub-divisions, local authorities or the Central Bank, and approved transactions may be exempt by the source State. Interest is defined as income from debt-claims, excludes penalty charges, is deemed to arise with a resident payer or when a permanent establishment or fixed base bears the indebtedness, and payments exceeding arm's-length amounts due to special relationships are limited to the arm's-length amount. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5422