https://www.taxtmi.com/acts?id=19347 Cross-border interest may be taxed in the recipient's residence, while the source State may tax interest but, if the recipient is the beneficial owner, source withholding is limited and its application coordinated by the competent authorities. Interest is exempt at source where beneficially owned by government entities or specified central banking and agreed governmental financial institutions. The Article broadly defines interest as income from debt-claims excluding penalties, attributes source by payer or by connection to a permanent establishment or fixed base, and confines treaty relief where related-party arrangements produce non-arm's-length interest. en-us Fri, 20 Mar 2015 16:16:43 +0530 Wed, 13 Nov 2024 16:48:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=19347 Cross-border interest may be taxed in the recipient's residence, while the source State may tax interest but, if the recipient is the beneficial owner, source withholding is limited and its application coordinated by the competent authorities. Interest is exempt at source where beneficially owned by government entities or specified central banking and agreed governmental financial institutions. The Article broadly defines interest as income from debt-claims excluding penalties, attributes source by payer or by connection to a permanent establishment or fixed base, and confines treaty relief where related-party arrangements produce non-arm's-length interest. Act-Rules DTAA Fri, 20 Mar 2015 16:16:43 +0530 https://www.taxtmi.com/acts?id=19347