https://www.taxtmi.com/acts?id=18241 Interest paid to a resident of the other Contracting State may be taxed in the recipient's State, while the source State may also tax that interest but must limit withholding where the beneficial owner is resident in the other State. Exemptions apply to specified governments, public authorities and designated banks, and additional institutions by mutual agreement. Interest covers income from debt-claims but excludes penalty charges. If the beneficial owner carries on business via a permanent establishment or fixed base and the debt is effectively connected, business profit or independent services rules apply. Special-relationship excess interest is limited to an arm's-length amount. en-us Sun, 23 Mar 2014 14:54:41 +0530 Wed, 28 Aug 2024 16:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18241 Interest paid to a resident of the other Contracting State may be taxed in the recipient's State, while the source State may also tax that interest but must limit withholding where the beneficial owner is resident in the other State. Exemptions apply to specified governments, public authorities and designated banks, and additional institutions by mutual agreement. Interest covers income from debt-claims but excludes penalty charges. If the beneficial owner carries on business via a permanent establishment or fixed base and the debt is effectively connected, business profit or independent services rules apply. Special-relationship excess interest is limited to an arm's-length amount. Act-Rules DTAA Sun, 23 Mar 2014 14:54:41 +0530 https://www.taxtmi.com/acts?id=18241