https://www.taxtmi.com/acts?id=16814 Article 11 permits residence state taxation of interest paid by a Contracting State but allows the source State to tax such interest subject to a capped rate where the beneficial owner is resident in the other Contracting State. Exemptions apply to central banks, governments and agreed institutions. Interest is broadly defined; interest is deemed to arise where the payer is resident or where a permanent establishment or fixed base bears the indebtedness. If the beneficial owner's interest is effectively connected to a permanent establishment or fixed base, Articles 7 or 14 govern. Related party excess interest is limited to arm's length amounts for treaty purposes. en-us Tue, 31 Jul 2012 13:01:54 +0530 Wed, 27 Nov 2024 13:08:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=16814 Article 11 permits residence state taxation of interest paid by a Contracting State but allows the source State to tax such interest subject to a capped rate where the beneficial owner is resident in the other Contracting State. Exemptions apply to central banks, governments and agreed institutions. Interest is broadly defined; interest is deemed to arise where the payer is resident or where a permanent establishment or fixed base bears the indebtedness. If the beneficial owner's interest is effectively connected to a permanent establishment or fixed base, Articles 7 or 14 govern. Related party excess interest is limited to arm's length amounts for treaty purposes. Act-Rules DTAA Tue, 31 Jul 2012 13:01:54 +0530 https://www.taxtmi.com/acts?id=16814