https://www.taxtmi.com/acts?id=34175 Interest arising in a Contracting Party may be taxed in the payer's state and may also be taxed in the recipient's residence, with a reduced withholding where the beneficial owner is resident of the other Contracting Party; exemptions apply for governments, specified central banking and public financial institutions, and agreed institutions. Preferential treatment is excluded if the beneficial owner operates through a permanent establishment or fixed base in the source state and the debt-claim is effectively connected; sourcing is generally where the payer is resident, arm's length adjustments address amounts inflated by special relationships, and benefits are denied for transactions whose main purpose is treaty advantage. en-us Fri, 28 Dec 2018 16:39:18 +0530 Thu, 21 Nov 2024 10:48:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=34175 Interest arising in a Contracting Party may be taxed in the payer's state and may also be taxed in the recipient's residence, with a reduced withholding where the beneficial owner is resident of the other Contracting Party; exemptions apply for governments, specified central banking and public financial institutions, and agreed institutions. Preferential treatment is excluded if the beneficial owner operates through a permanent establishment or fixed base in the source state and the debt-claim is effectively connected; sourcing is generally where the payer is resident, arm's length adjustments address amounts inflated by special relationships, and benefits are denied for transactions whose main purpose is treaty advantage. Act-Rules DTAA Fri, 28 Dec 2018 16:39:18 +0530 https://www.taxtmi.com/acts?id=34175