https://www.taxtmi.com/acts?id=45256 Article 11 allocates taxing rights over cross-border interest: residence States may tax interest paid to their residents, while source States may also tax such interest but are limited by specified withholding caps when the recipient is the beneficial owner. The Article defines interest as income from debt-claims, excludes penalty charges for late payment, and provides that permanent establishment or fixed base connections and special-relationship adjustments determine when business profits or arm's-length principles apply. en-us Thu, 17 Oct 2024 18:27:35 +0530 Tue, 22 Oct 2024 17:20:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45256 Article 11 allocates taxing rights over cross-border interest: residence States may tax interest paid to their residents, while source States may also tax such interest but are limited by specified withholding caps when the recipient is the beneficial owner. The Article defines interest as income from debt-claims, excludes penalty charges for late payment, and provides that permanent establishment or fixed base connections and special-relationship adjustments determine when business profits or arm's-length principles apply. Act-Rules DTAA Thu, 17 Oct 2024 18:27:35 +0530 https://www.taxtmi.com/acts?id=45256