https://www.taxtmi.com/acts?id=18161 may be taxed by the recipient's State, and the source State may tax such interest but must limit the tax to 10% of gross interest when the beneficial owner is resident in the other Contracting State. Specific exemptions apply where interest is beneficially owned by governments, specified central banks or agreed institutions. is defined as income from debt-claims (excluding penalty charges). is deemed to arise where the payer is resident unless a permanent establishment or fixed base bearing the indebtedness exists; if interest is effectively connected with such presence, provisions for business profits or independent personal services apply. Special-relationship adjustments limit treaty relief to the arm's-length amount. en-us Thu, 13 Feb 2014 12:08:58 +0530 Tue, 25 Nov 2025 16:06:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18161 may be taxed by the recipient's State, and the source State may tax such interest but must limit the tax to 10% of gross interest when the beneficial owner is resident in the other Contracting State. Specific exemptions apply where interest is beneficially owned by governments, specified central banks or agreed institutions. is defined as income from debt-claims (excluding penalty charges). is deemed to arise where the payer is resident unless a permanent establishment or fixed base bearing the indebtedness exists; if interest is effectively connected with such presence, provisions for business profits or independent personal services apply. Special-relationship adjustments limit treaty relief to the arm's-length amount. Act-Rules DTAA Thu, 13 Feb 2014 12:08:58 +0530 https://www.taxtmi.com/acts?id=18161