https://www.taxtmi.com/acts?id=41709 Article 11 permits taxation of interest by the recipient's State while allowing the source State to tax interest paid to a resident beneficial owner subject to a treaty withholding limit. It broadly defines interest as income from debt-claims, excludes income covered by other Articles, and provides that where interest is effectively connected to a permanent establishment or fixed base the business taxation rules apply. Where special relationships cause interest to exceed arm's-length amounts, treaty benefits apply only to the arm's-length portion and the excess is taxable under domestic law. en-us Fri, 05 May 2023 16:33:20 +0530 Fri, 08 Nov 2024 14:47:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=41709 Article 11 permits taxation of interest by the recipient's State while allowing the source State to tax interest paid to a resident beneficial owner subject to a treaty withholding limit. It broadly defines interest as income from debt-claims, excludes income covered by other Articles, and provides that where interest is effectively connected to a permanent establishment or fixed base the business taxation rules apply. Where special relationships cause interest to exceed arm's-length amounts, treaty benefits apply only to the arm's-length portion and the excess is taxable under domestic law. Act-Rules DTAA Fri, 05 May 2023 16:33:20 +0530 https://www.taxtmi.com/acts?id=41709