https://www.taxtmi.com/acts?id=44975 Taxation of cross-border interest grants primary taxing rights to the recipient's residence State while permitting source-State taxation subject to a cap when the beneficial owner resides in the other Contracting State. Exemptions apply for interest beneficially owned by the government and designated public financial institutions. Interest is defined broadly as income from debt-claims, excludes penalties, and is deemed to arise in the payer's State or where a permanent establishment or fixed base bearing the interest is situated. Interest connected to a permanent establishment or fixed base is taxed under business profits or independent services rules, and related-party excess interest is limited to an arm's-length amount. en-us Wed, 16 Oct 2024 17:33:42 +0530 Tue, 22 Oct 2024 11:41:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44975 Taxation of cross-border interest grants primary taxing rights to the recipient's residence State while permitting source-State taxation subject to a cap when the beneficial owner resides in the other Contracting State. Exemptions apply for interest beneficially owned by the government and designated public financial institutions. Interest is defined broadly as income from debt-claims, excludes penalties, and is deemed to arise in the payer's State or where a permanent establishment or fixed base bearing the interest is situated. Interest connected to a permanent establishment or fixed base is taxed under business profits or independent services rules, and related-party excess interest is limited to an arm's-length amount. Act-Rules DTAA Wed, 16 Oct 2024 17:33:42 +0530 https://www.taxtmi.com/acts?id=44975