https://www.taxtmi.com/acts?id=20120 The Article allocates interest taxation between residence and source states: residence may tax interest paid to its residents, while the source State may tax interest arising there subject to a capped rate when the beneficial owner is resident of the other Contracting State. Exemptions apply for governments, sub-national authorities and specified central and export-import banks or institutions agreed by competent authorities. Interest is broadly defined as income from debt-claims; penalties for late payment are excluded. Interest is sourced to the payer's State unless a permanent establishment or fixed base bears the indebtedness. Related-party excess interest is limited to arm's-length amounts, with excess taxable under domestic law. en-us Fri, 04 Dec 2015 14:18:51 +0530 Mon, 02 Dec 2024 11:27:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=20120 The Article allocates interest taxation between residence and source states: residence may tax interest paid to its residents, while the source State may tax interest arising there subject to a capped rate when the beneficial owner is resident of the other Contracting State. Exemptions apply for governments, sub-national authorities and specified central and export-import banks or institutions agreed by competent authorities. Interest is broadly defined as income from debt-claims; penalties for late payment are excluded. Interest is sourced to the payer's State unless a permanent establishment or fixed base bears the indebtedness. Related-party excess interest is limited to arm's-length amounts, with excess taxable under domestic law. Act-Rules DTAA Fri, 04 Dec 2015 14:18:51 +0530 https://www.taxtmi.com/acts?id=20120