https://www.taxtmi.com/acts?id=6025 Interest may be taxed in the recipient State, but the source State may also impose withholding tax subject to caps where the recipient is the beneficial owner; exemptions apply for Governments, central banks and certain export-import banks. The Article treats income from all debt-claims as interest, excludes withholding treatment when interest is effectively connected with a permanent establishment, and requires arm's-length adjustment where related-party relationships inflate interest payments. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 03 Dec 2024 10:16:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6025 Interest may be taxed in the recipient State, but the source State may also impose withholding tax subject to caps where the recipient is the beneficial owner; exemptions apply for Governments, central banks and certain export-import banks. The Article treats income from all debt-claims as interest, excludes withholding treatment when interest is effectively connected with a permanent establishment, and requires arm's-length adjustment where related-party relationships inflate interest payments. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6025