https://www.taxtmi.com/acts?id=44945 Article 11 provides that interest arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State, while the source State may also tax it subject to a Convention ceiling when the recipient is the beneficial owner. Exceptions permit exclusive residence state taxation where interest is beneficially owned by government entities or specified wholly government owned financial institutions, or where debt claims are government guaranteed or indirectly financed. Interest is broadly defined and special relationship and permanent establishment rules limit Article 11's application. en-us Wed, 16 Oct 2024 17:19:25 +0530 Tue, 22 Oct 2024 14:50:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44945 Article 11 provides that interest arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State, while the source State may also tax it subject to a Convention ceiling when the recipient is the beneficial owner. Exceptions permit exclusive residence state taxation where interest is beneficially owned by government entities or specified wholly government owned financial institutions, or where debt claims are government guaranteed or indirectly financed. Interest is broadly defined and special relationship and permanent establishment rules limit Article 11's application. Act-Rules DTAA Wed, 16 Oct 2024 17:19:25 +0530 https://www.taxtmi.com/acts?id=44945