https://www.taxtmi.com/acts?id=14923 arising in one Contracting State paid to a resident of the other may be taxed in the recipient's State, but the source State may also tax such interest subject to a reduced withholding limit when the beneficial owner is resident of the other State. Exemptions allocate exclusive rights where interest is paid to specified government bodies or public financial institutions, and loans guaranteed by such bodies are taxable only in the recipient State. Connection to a permanent establishment or fixed base makes the interest taxable under business profits or independent services rules. is deemed to arise where the payer resides unless a permanent establishment or fixed base bears the indebtedness. Related-party excess interest is limited to arm's-length amounts. en-us Tue, 30 Aug 2011 11:39:57 +0530 Mon, 18 Nov 2024 18:21:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=14923 arising in one Contracting State paid to a resident of the other may be taxed in the recipient's State, but the source State may also tax such interest subject to a reduced withholding limit when the beneficial owner is resident of the other State. Exemptions allocate exclusive rights where interest is paid to specified government bodies or public financial institutions, and loans guaranteed by such bodies are taxable only in the recipient State. Connection to a permanent establishment or fixed base makes the interest taxable under business profits or independent services rules. is deemed to arise where the payer resides unless a permanent establishment or fixed base bears the indebtedness. Related-party excess interest is limited to arm's-length amounts. Act-Rules DTAA Tue, 30 Aug 2011 11:39:57 +0530 https://www.taxtmi.com/acts?id=14923