https://www.taxtmi.com/acts?id=45039 Article 11 limits source taxation of interest paid to a resident beneficial owner to 10% of gross interest while providing exemptions for specified governmental and public financial institutions. Interest is broadly defined as income from debt claims, excludes penalties and amounts treated as dividends, and is deemed to arise where the payer is resident unless tied to a permanent establishment or fixed base, in which case it arises where that establishment or base is situated. Related party excess interest is restricted to an arm's length amount for treaty relief. en-us Wed, 16 Oct 2024 18:11:01 +0530 Tue, 22 Oct 2024 12:52:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45039 Article 11 limits source taxation of interest paid to a resident beneficial owner to 10% of gross interest while providing exemptions for specified governmental and public financial institutions. Interest is broadly defined as income from debt claims, excludes penalties and amounts treated as dividends, and is deemed to arise where the payer is resident unless tied to a permanent establishment or fixed base, in which case it arises where that establishment or base is situated. Related party excess interest is restricted to an arm's length amount for treaty relief. Act-Rules DTAA Wed, 16 Oct 2024 18:11:01 +0530 https://www.taxtmi.com/acts?id=45039