https://www.taxtmi.com/acts?id=8345 Article 11 permits taxation of interest by the recipient's State while allowing source-state taxation subject to a capped tax where the beneficial owner is resident of the other State; certain governmental and specified public financial institutions are exempt. "Interest" covers income from debt claims broadly, excluding late-payment penalties. Interest effectively connected to a permanent establishment or fixed base is treated as arising in the State of that establishment and is taxed under business or professional profit rules. Payments inflated by special relationships are limited to the arm's-length amount for treaty benefits, with excess taxable under domestic law. en-us Sun, 10 Feb 2008 21:49:04 +0530 Fri, 15 Nov 2024 16:14:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=8345 Article 11 permits taxation of interest by the recipient's State while allowing source-state taxation subject to a capped tax where the beneficial owner is resident of the other State; certain governmental and specified public financial institutions are exempt. "Interest" covers income from debt claims broadly, excluding late-payment penalties. Interest effectively connected to a permanent establishment or fixed base is treated as arising in the State of that establishment and is taxed under business or professional profit rules. Payments inflated by special relationships are limited to the arm's-length amount for treaty benefits, with excess taxable under domestic law. Act-Rules DTAA Sun, 10 Feb 2008 21:49:04 +0530 https://www.taxtmi.com/acts?id=8345