https://www.taxtmi.com/acts?id=45138 Primary taxing rights over interest are allocated to the recipient's State while the source State may tax interest paid to a beneficial owner subject to a limitation; governments and government-guaranteed loan interest are exempt. The Article defines interest as income from debt-claims (excluding penalty charges) and includes examples. Interest connected to a permanent establishment or fixed base is taxed where that establishment or base is situated, and where related-party relationships inflate interest, only the arm's-length amount falls under the Article, the excess remaining taxable under domestic law. en-us Thu, 17 Oct 2024 15:35:20 +0530 Wed, 23 Oct 2024 16:32:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45138 Primary taxing rights over interest are allocated to the recipient's State while the source State may tax interest paid to a beneficial owner subject to a limitation; governments and government-guaranteed loan interest are exempt. The Article defines interest as income from debt-claims (excluding penalty charges) and includes examples. Interest connected to a permanent establishment or fixed base is taxed where that establishment or base is situated, and where related-party relationships inflate interest, only the arm's-length amount falls under the Article, the excess remaining taxable under domestic law. Act-Rules DTAA Thu, 17 Oct 2024 15:35:20 +0530 https://www.taxtmi.com/acts?id=45138