https://www.taxtmi.com/acts?id=16749 Cross-border interest payments are taxable in the recipient's residence State, while the source State may also tax such interest but at a reduced rate when the beneficial owner is resident in the other Contracting State; specified public entities and mutually agreed institutions are exempt. Interest is defined as income from debt claims, excluding dividends and penalty charges. A permanent establishment or fixed base connection places taxation under business or independent services rules, and special relationship adjustments limit treaty relief to arm's length interest amounts. en-us Tue, 31 Jul 2012 11:42:05 +0530 Sat, 16 Nov 2024 12:38:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=16749 Cross-border interest payments are taxable in the recipient's residence State, while the source State may also tax such interest but at a reduced rate when the beneficial owner is resident in the other Contracting State; specified public entities and mutually agreed institutions are exempt. Interest is defined as income from debt claims, excluding dividends and penalty charges. A permanent establishment or fixed base connection places taxation under business or independent services rules, and special relationship adjustments limit treaty relief to arm's length interest amounts. Act-Rules DTAA Tue, 31 Jul 2012 11:42:05 +0530 https://www.taxtmi.com/acts?id=16749