https://www.taxtmi.com/acts?id=32269 Cross-border interest is taxable in the recipient's residence, but the source State may tax interest arising there with withholding limited to ten per cent of gross interest when the beneficial owner is resident of the other Contracting State. Interest is exempt in the source State if beneficially owned by the other State, its political subdivisions or local authorities, designated central banks, or agreed government financial institutions. Interest is deemed to arise where the payer is resident, except when a permanent establishment or fixed base bears the indebtedness, in which case it is deemed to arise where that establishment or base is situated. Special-relationship excess is limited to the arm's length amount for treaty relief. en-us Tue, 15 May 2018 17:29:35 +0530 Mon, 09 Dec 2024 11:25:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=32269 Cross-border interest is taxable in the recipient's residence, but the source State may tax interest arising there with withholding limited to ten per cent of gross interest when the beneficial owner is resident of the other Contracting State. Interest is exempt in the source State if beneficially owned by the other State, its political subdivisions or local authorities, designated central banks, or agreed government financial institutions. Interest is deemed to arise where the payer is resident, except when a permanent establishment or fixed base bears the indebtedness, in which case it is deemed to arise where that establishment or base is situated. Special-relationship excess is limited to the arm's length amount for treaty relief. Act-Rules DTAA Tue, 15 May 2018 17:29:35 +0530 https://www.taxtmi.com/acts?id=32269