https://www.taxtmi.com/acts?id=6193 Interest arising in a Contracting State may be taxed in the recipient's State of residence, but the State where the interest arises may also tax it subject to a withholding limitation when the recipient is the beneficial owner. The Article defines interest broadly, attributes source to payers or to permanent establishments bearing the indebtedness, excludes treaty relief where interest is effectively connected with a permanent establishment or fixed base, limits treaty application to arm's length amounts in related party situations, contains an anti abuse main purpose rule, and exempts interest beneficially owned by the other State, its political subdivisions or central bank, or other approved residents. en-us Sat, 19 Jan 2008 22:45:54 +0530 Sat, 23 Nov 2024 10:46:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6193 Interest arising in a Contracting State may be taxed in the recipient's State of residence, but the State where the interest arises may also tax it subject to a withholding limitation when the recipient is the beneficial owner. The Article defines interest broadly, attributes source to payers or to permanent establishments bearing the indebtedness, excludes treaty relief where interest is effectively connected with a permanent establishment or fixed base, limits treaty application to arm's length amounts in related party situations, contains an anti abuse main purpose rule, and exempts interest beneficially owned by the other State, its political subdivisions or central bank, or other approved residents. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6193