https://www.taxtmi.com/acts?id=44820 Interest paid to a resident of the other Contracting State may be taxed in the recipient's State, while the source State may also tax such interest subject to a statutory limit when the beneficial owner is resident of the other State. Exemptions from source taxation apply for specified governmental and public financial institutions as agreed by Competent Authorities. The Article defines interest broadly, excludes penalty charges, deems interest to arise where the payer or relevant permanent establishment/fixed base is located, and limits treaty benefits to the arm's length portion where related party relationships inflate interest. en-us Wed, 16 Oct 2024 15:37:11 +0530 Tue, 22 Oct 2024 13:02:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44820 Interest paid to a resident of the other Contracting State may be taxed in the recipient's State, while the source State may also tax such interest subject to a statutory limit when the beneficial owner is resident of the other State. Exemptions from source taxation apply for specified governmental and public financial institutions as agreed by Competent Authorities. The Article defines interest broadly, excludes penalty charges, deems interest to arise where the payer or relevant permanent establishment/fixed base is located, and limits treaty benefits to the arm's length portion where related party relationships inflate interest. Act-Rules DTAA Wed, 16 Oct 2024 15:37:11 +0530 https://www.taxtmi.com/acts?id=44820