https://www.taxtmi.com/acts?id=6084 The treaty permits residence-state taxation of interest but allows the source State to tax interest paid to a beneficial owner subject to capped withholding rates; interest derived and beneficially owned by the Government, a political subdivision or a Central Bank of the other Contracting State is exempt. The Article broadly defines interest as income from debt-claims, excludes late-payment penalties, disapplies withholding limits where the beneficial owner's permanent establishment or fixed base is effectively connected with the debt, and limits treaty relief where related-party relationships inflate interest above arm's-length amounts. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 03 Dec 2024 12:17:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6084 The treaty permits residence-state taxation of interest but allows the source State to tax interest paid to a beneficial owner subject to capped withholding rates; interest derived and beneficially owned by the Government, a political subdivision or a Central Bank of the other Contracting State is exempt. The Article broadly defines interest as income from debt-claims, excludes late-payment penalties, disapplies withholding limits where the beneficial owner's permanent establishment or fixed base is effectively connected with the debt, and limits treaty relief where related-party relationships inflate interest above arm's-length amounts. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6084