https://www.taxtmi.com/acts?id=5694 Cross-border interest may be taxed in the recipient's residence State, while the source State may also tax interest but with a reduced withholding where the recipient is the beneficial owner. Governmental and specified public bank recipients are exempt in the source State when beneficially owned. is broadly defined to include income from debt-claims and related premiums; penalties for late payment are excluded. The reduced withholding does not apply if the beneficial owner has a permanent establishment or fixed base in the source State and the debt is effectively connected; in that case business profits or independent personal services rules govern. is sourced to the payer's State, with arm's-length adjustments where special relationships inflate payments. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 26 Nov 2024 12:02:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5694 Cross-border interest may be taxed in the recipient's residence State, while the source State may also tax interest but with a reduced withholding where the recipient is the beneficial owner. Governmental and specified public bank recipients are exempt in the source State when beneficially owned. is broadly defined to include income from debt-claims and related premiums; penalties for late payment are excluded. The reduced withholding does not apply if the beneficial owner has a permanent establishment or fixed base in the source State and the debt is effectively connected; in that case business profits or independent personal services rules govern. is sourced to the payer's State, with arm's-length adjustments where special relationships inflate payments. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5694