https://www.taxtmi.com/acts?id=6163 Article 12 permits taxation of interest in the recipient's State while allowing the source State to tax such interest subject to capped withholding when the recipient is the beneficial owner; special reduced or full exemptions apply for bona fide banks and governmental entities, and specified export-credit-guaranteed debt. The withholding limits do not apply if the beneficial owner's interest is effectively connected with a permanent establishment or fixed base in the source State, in which case business profits or independent personal services rules apply. Related-party excess interest is limited to arm's-length amounts, and treaty relief is denied where treaty benefits were a main purpose of the transaction. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 08 Oct 2024 10:29:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6163 Article 12 permits taxation of interest in the recipient's State while allowing the source State to tax such interest subject to capped withholding when the recipient is the beneficial owner; special reduced or full exemptions apply for bona fide banks and governmental entities, and specified export-credit-guaranteed debt. The withholding limits do not apply if the beneficial owner's interest is effectively connected with a permanent establishment or fixed base in the source State, in which case business profits or independent personal services rules apply. Related-party excess interest is limited to arm's-length amounts, and treaty relief is denied where treaty benefits were a main purpose of the transaction. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6163