https://www.taxtmi.com/acts?id=45072 Article 11 limits taxation of interest: interest paid to a resident of the other Contracting State may be taxed in that other State, and may also be taxed in the source State but, if the beneficial owner is a resident of the other State, source taxation is capped at ten percent of the gross amount. Exemptions apply where interest is beneficially owned by governments or specified financial institutions, with additional institutions includable by mutual agreement. The Article defines interest broadly, excludes late-payment penalties, treats interest connected to a permanent establishment or fixed base as sourced to that State, and requires arm's-length adjustment where related-party relationships inflate interest. en-us Wed, 16 Oct 2024 18:24:49 +0530 Tue, 22 Oct 2024 14:20:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45072 Article 11 limits taxation of interest: interest paid to a resident of the other Contracting State may be taxed in that other State, and may also be taxed in the source State but, if the beneficial owner is a resident of the other State, source taxation is capped at ten percent of the gross amount. Exemptions apply where interest is beneficially owned by governments or specified financial institutions, with additional institutions includable by mutual agreement. The Article defines interest broadly, excludes late-payment penalties, treats interest connected to a permanent establishment or fixed base as sourced to that State, and requires arm's-length adjustment where related-party relationships inflate interest. Act-Rules DTAA Wed, 16 Oct 2024 18:24:49 +0530 https://www.taxtmi.com/acts?id=45072