https://www.taxtmi.com/acts?id=44665 Cross-border interest may be taxed by the residence state and by the source state, but source taxation of interest payable to the beneficial owner resident in the other Contracting State is limited; exemptions apply for public entities and specified financial institutions. is defined broadly as income from debt claims excluding penalty charges. Where the beneficial owner carries on business through a permanent establishment or fixed base to which the debt is effectively connected, provisions on business profits or independent personal services govern. is deemed to arise where the payer resides unless attributable to a permanent establishment or fixed base, and amounts above arm's-length are excluded from the Article's treatment. en-us Wed, 16 Oct 2024 12:43:44 +0530 Tue, 22 Oct 2024 11:31:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44665 Cross-border interest may be taxed by the residence state and by the source state, but source taxation of interest payable to the beneficial owner resident in the other Contracting State is limited; exemptions apply for public entities and specified financial institutions. is defined broadly as income from debt claims excluding penalty charges. Where the beneficial owner carries on business through a permanent establishment or fixed base to which the debt is effectively connected, provisions on business profits or independent personal services govern. is deemed to arise where the payer resides unless attributable to a permanent establishment or fixed base, and amounts above arm's-length are excluded from the Article's treatment. Act-Rules DTAA Wed, 16 Oct 2024 12:43:44 +0530 https://www.taxtmi.com/acts?id=44665