https://www.taxtmi.com/acts?id=37674 Taxing rights over cross-border interest allocate to both the source State and the recipient's State: the source State may tax interest arising within it but, where the beneficial owner is a resident of the other Contracting State, the tax on gross interest is limited and certain public entities and specified financial institutions of the other State are exempt. Interest is defined as income from debt-claims (excluding penalty charges), deemed to arise where the payer resides or where a permanent establishment or fixed base bears the indebtedness, and amounts inflated by special relationships are confined to arm's-length amounts. en-us Thu, 19 Sep 2019 12:56:54 +0530 Mon, 09 Dec 2024 11:36:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=37674 Taxing rights over cross-border interest allocate to both the source State and the recipient's State: the source State may tax interest arising within it but, where the beneficial owner is a resident of the other Contracting State, the tax on gross interest is limited and certain public entities and specified financial institutions of the other State are exempt. Interest is defined as income from debt-claims (excluding penalty charges), deemed to arise where the payer resides or where a permanent establishment or fixed base bears the indebtedness, and amounts inflated by special relationships are confined to arm's-length amounts. Act-Rules DTAA Thu, 19 Sep 2019 12:56:54 +0530 https://www.taxtmi.com/acts?id=37674