https://www.taxtmi.com/acts?id=5453 Article 12 limits source-State taxation of cross-border interest paid to a beneficial owner by prescribing reduced withholding rates and by exempting interest beneficially owned by Governments, the Central Bank and specified lending institutions; an additional Government-approved exemption may apply to other resident beneficiaries. Interest effectively connected with a permanent establishment or fixed base is treated as business or independent personal service income and taxed under the provisions for such income. The Article defines interest broadly as income from debt-claims, excluding penalty charges for late payment, and requires related-party pricing adjustments to apply arm's-length amounts. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 19 Dec 2024 10:08:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5453 Article 12 limits source-State taxation of cross-border interest paid to a beneficial owner by prescribing reduced withholding rates and by exempting interest beneficially owned by Governments, the Central Bank and specified lending institutions; an additional Government-approved exemption may apply to other resident beneficiaries. Interest effectively connected with a permanent establishment or fixed base is treated as business or independent personal service income and taxed under the provisions for such income. The Article defines interest broadly as income from debt-claims, excluding penalty charges for late payment, and requires related-party pricing adjustments to apply arm's-length amounts. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5453