https://www.taxtmi.com/acts?id=44789 The Article permits taxation of interest in the recipient's State of residence but allows source-state taxation limited by a specified withholding cap when the beneficial owner resides in the other Contracting State. Exceptions grant exclusive source or residence taxation when interest is paid to designated public or state-owned bodies, and guaranteed loans to such bodies are taxed only in the other State. Interest is defined to include income from all debt-claims (excluding late-payment penalties), arises where the payer is resident unless connected to a PE or fixed base, and related-party excess interest is disallowed from treaty benefits and remains taxable under domestic law. en-us Wed, 16 Oct 2024 15:05:03 +0530 Tue, 22 Oct 2024 14:10:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44789 The Article permits taxation of interest in the recipient's State of residence but allows source-state taxation limited by a specified withholding cap when the beneficial owner resides in the other Contracting State. Exceptions grant exclusive source or residence taxation when interest is paid to designated public or state-owned bodies, and guaranteed loans to such bodies are taxed only in the other State. Interest is defined to include income from all debt-claims (excluding late-payment penalties), arises where the payer is resident unless connected to a PE or fixed base, and related-party excess interest is disallowed from treaty benefits and remains taxable under domestic law. Act-Rules DTAA Wed, 16 Oct 2024 15:05:03 +0530 https://www.taxtmi.com/acts?id=44789