https://www.taxtmi.com/acts?id=44696 Article 11 permits residence taxation of interest and allows source taxation subject to a reduced withholding limit when the recipient is the beneficial owner; exemptions cover government payers, central banks and agreed agencies, and specified export credit related interest is taxable only in the borrower's residence. is defined broadly as income from debt claims; interest borne by a permanent establishment or fixed base is deemed to arise in the State of that establishment, and where the beneficial owner's activities connect the debt claim to a permanent establishment or fixed base, business or independent personal services rules apply. Amounts exceeding arm's length interest because of special relationships may be adjusted and taxed under domestic law. en-us Wed, 16 Oct 2024 13:14:42 +0530 Wed, 23 Oct 2024 16:18:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44696 Article 11 permits residence taxation of interest and allows source taxation subject to a reduced withholding limit when the recipient is the beneficial owner; exemptions cover government payers, central banks and agreed agencies, and specified export credit related interest is taxable only in the borrower's residence. is defined broadly as income from debt claims; interest borne by a permanent establishment or fixed base is deemed to arise in the State of that establishment, and where the beneficial owner's activities connect the debt claim to a permanent establishment or fixed base, business or independent personal services rules apply. Amounts exceeding arm's length interest because of special relationships may be adjusted and taxed under domestic law. Act-Rules DTAA Wed, 16 Oct 2024 13:14:42 +0530 https://www.taxtmi.com/acts?id=44696