https://www.taxtmi.com/acts?id=15122 The treaty permits both the residence State of the beneficial owner and the source State to tax cross-border interest, but limits source State taxation when the beneficial owner is resident of the other Contracting State; interest arising in the source State is exempt if beneficially owned by governments, specified public financial institutions, or other agreed institutions. The Article defines interest broadly, deems interest to arise where the payer or the payer's permanent establishment is resident, disapplies the withholding limit when the interest is effectively connected to a permanent establishment or fixed base, and requires arm's-length adjustment where related-party relationships inflate interest. en-us Tue, 30 Aug 2011 15:25:24 +0530 Fri, 22 Nov 2024 14:39:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=15122 The treaty permits both the residence State of the beneficial owner and the source State to tax cross-border interest, but limits source State taxation when the beneficial owner is resident of the other Contracting State; interest arising in the source State is exempt if beneficially owned by governments, specified public financial institutions, or other agreed institutions. The Article defines interest broadly, deems interest to arise where the payer or the payer's permanent establishment is resident, disapplies the withholding limit when the interest is effectively connected to a permanent establishment or fixed base, and requires arm's-length adjustment where related-party relationships inflate interest. Act-Rules DTAA Tue, 30 Aug 2011 15:25:24 +0530 https://www.taxtmi.com/acts?id=15122