https://www.taxtmi.com/acts?id=45201 The treaty allows residence-state taxation of interest paid to its residents but permits source-state taxation subject to a treaty cap when the recipient is the beneficial owner; exemptions apply where interest is derived and beneficially owned by the other State, its political subdivisions, the Central Bank, or agreed governmental agencies. Interest is defined broadly as income from debt-claims, excluding penalty charges. Where the beneficial owner's interest is effectively connected with a permanent establishment or fixed base in the source State, business or independent services rules apply. Special relationships producing excess interest are limited to arm's-length amounts for treaty treatment. en-us Thu, 17 Oct 2024 16:45:30 +0530 Tue, 22 Oct 2024 16:44:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45201 The treaty allows residence-state taxation of interest paid to its residents but permits source-state taxation subject to a treaty cap when the recipient is the beneficial owner; exemptions apply where interest is derived and beneficially owned by the other State, its political subdivisions, the Central Bank, or agreed governmental agencies. Interest is defined broadly as income from debt-claims, excluding penalty charges. Where the beneficial owner's interest is effectively connected with a permanent establishment or fixed base in the source State, business or independent services rules apply. Special relationships producing excess interest are limited to arm's-length amounts for treaty treatment. Act-Rules DTAA Thu, 17 Oct 2024 16:45:30 +0530 https://www.taxtmi.com/acts?id=45201