https://www.taxtmi.com/acts?id=18004 Article 11 allocates taxation of interest to the recipient's residence while allowing source-state taxation subject to a capped withholding when the beneficial owner is a resident of the other Contracting State, with exemptions for governments, specified central banks and agreed institutions. The Article defines interest, excludes penalties, treats interest as arising in the payer's State unless attributable to a permanent establishment or fixed base, and restricts treaty relief where related-party relationships cause non arm's length interest. en-us Mon, 22 Jul 2013 16:43:55 +0530 Mon, 18 Nov 2024 12:17:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18004 Article 11 allocates taxation of interest to the recipient's residence while allowing source-state taxation subject to a capped withholding when the beneficial owner is a resident of the other Contracting State, with exemptions for governments, specified central banks and agreed institutions. The Article defines interest, excludes penalties, treats interest as arising in the payer's State unless attributable to a permanent establishment or fixed base, and restricts treaty relief where related-party relationships cause non arm's length interest. Act-Rules DTAA Mon, 22 Jul 2013 16:43:55 +0530 https://www.taxtmi.com/acts?id=18004