https://www.taxtmi.com/acts?id=16568 Interest may be taxed in the residence State, while the source State may tax such interest subject to a withholding limitation when the beneficial owner is resident in the other Contracting State; designated public and governmental institutions may be exempt from source tax by express listing. Interest is broadly defined as income from debt-claims excluding penalty charges. Deemed-source rules attribute interest to the payer's residence unless tied to a permanent establishment or fixed base, in which case connection to that presence governs and anti-abuse adjustments apply to amounts exceeding arm's-length interest. en-us Wed, 30 May 2012 15:47:26 +0530 Tue, 19 Nov 2024 18:06:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=16568 Interest may be taxed in the residence State, while the source State may tax such interest subject to a withholding limitation when the beneficial owner is resident in the other Contracting State; designated public and governmental institutions may be exempt from source tax by express listing. Interest is broadly defined as income from debt-claims excluding penalty charges. Deemed-source rules attribute interest to the payer's residence unless tied to a permanent establishment or fixed base, in which case connection to that presence governs and anti-abuse adjustments apply to amounts exceeding arm's-length interest. Act-Rules DTAA Wed, 30 May 2012 15:47:26 +0530 https://www.taxtmi.com/acts?id=16568