https://www.taxtmi.com/article/detailed?id=8643 Article 11 grants the residence state primary taxing rights over cross-border Interest while permitting the source state a limited taxing right capped where the recipient is the beneficial owner resident of the other state; Article 11 also defines interest exhaustively for treaty purposes, displaces the article where interest is effectively connected to a permanent establishment (so that business profits rules apply), and conditions reduced source taxation on arm's-length pricing between related parties. en-us Tue, 30 Jul 2019 06:26:22 +0530 Tue, 30 Jul 2019 09:35:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=8643 Article 11 grants the residence state primary taxing rights over cross-border Interest while permitting the source state a limited taxing right capped where the recipient is the beneficial owner resident of the other state; Article 11 also defines interest exhaustively for treaty purposes, displaces the article where interest is effectively connected to a permanent establishment (so that business profits rules apply), and conditions reduced source taxation on arm's-length pricing between related parties. Articles Income Tax Tue, 30 Jul 2019 06:26:22 +0530 https://www.taxtmi.com/article/detailed?id=8643