https://www.taxtmi.com/acts?id=16859 Article 11 permits taxation of interest in the recipient's State while allowing the source State to tax such interest subject to a capped source tax when the beneficial owner is resident in the other State; specified public bodies and agreed institutions are exempt. Interest is defined as income from debt claims (excluding late-payment penalties). Interest effectively connected to a permanent establishment or fixed base is treated as arising in the State of that establishment and governed by Articles 7 or 14. Amounts exceeding arm's-length interest due to special relationships are taxable only to the arm's-length portion under the Article. en-us Fri, 03 Aug 2012 18:36:31 +0530 Mon, 02 Sep 2024 14:17:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=16859 Article 11 permits taxation of interest in the recipient's State while allowing the source State to tax such interest subject to a capped source tax when the beneficial owner is resident in the other State; specified public bodies and agreed institutions are exempt. Interest is defined as income from debt claims (excluding late-payment penalties). Interest effectively connected to a permanent establishment or fixed base is treated as arising in the State of that establishment and governed by Articles 7 or 14. Amounts exceeding arm's-length interest due to special relationships are taxable only to the arm's-length portion under the Article. Act-Rules DTAA Fri, 03 Aug 2012 18:36:31 +0530 https://www.taxtmi.com/acts?id=16859