https://www.taxtmi.com/acts?id=16781 The DTAA provides that interest arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State, but may also be taxed at source subject to a withholding cap when the beneficial owner is resident in the other State; exemptions apply for government and designated financial institutions. Interest is broadly defined as income from debt claims, excludes dividend treatment and late payment penalties, is sourced to the payer unless attributable to a permanent establishment or fixed base, and is limited by an arm's length rule where related party relationships inflate interest. en-us Tue, 31 Jul 2012 12:30:34 +0530 Tue, 26 Nov 2024 10:55:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=16781 The DTAA provides that interest arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State, but may also be taxed at source subject to a withholding cap when the beneficial owner is resident in the other State; exemptions apply for government and designated financial institutions. Interest is broadly defined as income from debt claims, excludes dividend treatment and late payment penalties, is sourced to the payer unless attributable to a permanent establishment or fixed base, and is limited by an arm's length rule where related party relationships inflate interest. Act-Rules DTAA Tue, 31 Jul 2012 12:30:34 +0530 https://www.taxtmi.com/acts?id=16781