https://www.taxtmi.com/manuals?id=4461 The Article allocates taxing rights over cross-border interest: resident States may tax received interest while source States may tax subject to a treaty limitation negotiated by competent authorities. Exceptions apply where the beneficial owner's interest is effectively connected with a permanent establishment or fixed base in the source State, in which case business profits or independent personal services rules govern. Interest is deemed to arise where the payer resides unless the indebtedness is linked to a permanent establishment or fixed base, and related-party excess interest is limited to arm's-length amounts for treaty relief. en-us Tue, 06 Feb 2024 16:05:00 +0530 Wed, 14 Feb 2024 17:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=4461 The Article allocates taxing rights over cross-border interest: resident States may tax received interest while source States may tax subject to a treaty limitation negotiated by competent authorities. Exceptions apply where the beneficial owner's interest is effectively connected with a permanent establishment or fixed base in the source State, in which case business profits or independent personal services rules govern. Interest is deemed to arise where the payer resides unless the indebtedness is linked to a permanent establishment or fixed base, and related-party excess interest is limited to arm's-length amounts for treaty relief. Manuals Income Tax Tue, 06 Feb 2024 16:05:00 +0530 https://www.taxtmi.com/manuals?id=4461