https://www.taxtmi.com/acts?id=18907 Interest paid across Contracting States may be taxed in the recipient's State, while the source State may tax such interest subject to a withholding tax cap when the beneficial owner is resident of the other State; exemptions apply for governments and specified financial institutions. The Article defines interest broadly, excludes penalty charges, treats interest as arising where the payer is resident (with a deemed source rule tied to permanent establishments or fixed bases), disapplies withholding rules for interest effectively connected to a permanent establishment or fixed base, and restricts treaty treatment to arm's length interest where special relationships exist. en-us Tue, 12 Aug 2014 13:40:17 +0530 Tue, 26 Nov 2024 18:06:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18907 Interest paid across Contracting States may be taxed in the recipient's State, while the source State may tax such interest subject to a withholding tax cap when the beneficial owner is resident of the other State; exemptions apply for governments and specified financial institutions. The Article defines interest broadly, excludes penalty charges, treats interest as arising where the payer is resident (with a deemed source rule tied to permanent establishments or fixed bases), disapplies withholding rules for interest effectively connected to a permanent establishment or fixed base, and restricts treaty treatment to arm's length interest where special relationships exist. Act-Rules DTAA Tue, 12 Aug 2014 13:40:17 +0530 https://www.taxtmi.com/acts?id=18907