https://www.taxtmi.com/acts?id=45169 Article 11 allocates taxing rights over interest: interest paid to a resident may be taxed in the recipient's State and may also be taxed in the source State subject to a limited withholding where the beneficial owner is a resident. Interest paid to specified wholly government owned institutions is taxable only in the recipient's State. The Article defines interest comprehensively, excludes late payment penalties, carves out amounts effectively connected with a permanent establishment or fixed base to Articles 7/14, sets source rules based on payer residence or attributable permanent establishment, and applies an arm's length adjustment for special relationships. en-us Thu, 17 Oct 2024 16:17:07 +0530 Tue, 22 Oct 2024 12:26:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45169 Article 11 allocates taxing rights over interest: interest paid to a resident may be taxed in the recipient's State and may also be taxed in the source State subject to a limited withholding where the beneficial owner is a resident. Interest paid to specified wholly government owned institutions is taxable only in the recipient's State. The Article defines interest comprehensively, excludes late payment penalties, carves out amounts effectively connected with a permanent establishment or fixed base to Articles 7/14, sets source rules based on payer residence or attributable permanent establishment, and applies an arm's length adjustment for special relationships. Act-Rules DTAA Thu, 17 Oct 2024 16:17:07 +0530 https://www.taxtmi.com/acts?id=45169