https://www.taxtmi.com/acts?id=44634 paid to a resident of the other Contracting State may be taxed in the recipient's State, but the source State may tax such interest subject to a withholding tax not exceeding 10 per cent of the gross amount where the beneficial owner is a resident of the other State. Exemptions from source taxation apply for interest beneficially owned by or connected with loans extended or endorsed by specified governmental or public financial institutions or other institutions agreed by the competent authorities. The Article defines "interest," addresses permanent establishment connections that shift taxation to business profit or service provisions, sets deeming rules for source, and requires arm's-length adjustment where special relationships affect interest amounts. en-us Wed, 16 Oct 2024 12:13:25 +0530 Tue, 22 Oct 2024 16:33:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44634 paid to a resident of the other Contracting State may be taxed in the recipient's State, but the source State may tax such interest subject to a withholding tax not exceeding 10 per cent of the gross amount where the beneficial owner is a resident of the other State. Exemptions from source taxation apply for interest beneficially owned by or connected with loans extended or endorsed by specified governmental or public financial institutions or other institutions agreed by the competent authorities. The Article defines "interest," addresses permanent establishment connections that shift taxation to business profit or service provisions, sets deeming rules for source, and requires arm's-length adjustment where special relationships affect interest amounts. Act-Rules DTAA Wed, 16 Oct 2024 12:13:25 +0530 https://www.taxtmi.com/acts?id=44634