https://www.taxtmi.com/acts?id=5605 Article 11 permits source-state taxation of interest paid to residents of the other Contracting State but caps the source-state tax where the recipient is the beneficial owner; it exempts interest beneficially owned by the other State's government, political subdivisions, Central Bank, or agreed governmental agencies. "Interest" is income from debt-claims, excluding penalties. If the beneficial owner's business is connected to the source State via a permanent establishment or fixed base and the debt is effectively connected, the provisions of the treaty for business profits or independent personal services apply. Special-relationship excess interest is limited to arm's length treatment under the Article. en-us Sat, 19 Jan 2008 22:45:54 +0530 Wed, 28 Aug 2024 16:48:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5605 Article 11 permits source-state taxation of interest paid to residents of the other Contracting State but caps the source-state tax where the recipient is the beneficial owner; it exempts interest beneficially owned by the other State's government, political subdivisions, Central Bank, or agreed governmental agencies. "Interest" is income from debt-claims, excluding penalties. If the beneficial owner's business is connected to the source State via a permanent establishment or fixed base and the debt is effectively connected, the provisions of the treaty for business profits or independent personal services apply. Special-relationship excess interest is limited to arm's length treatment under the Article. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5605