https://www.taxtmi.com/acts?id=45351 Article 12 permits both the recipient's State and the source State to tax interest, but limits source withholding when the recipient is the beneficial owner; exemptions apply for interest beneficially owned by governments and the central bank, and additional exemptions may be granted with governmental approval. Interest is defined broadly, penalty charges are excluded, and nexus rules direct taxation to business profits or independent services when interest is effectively connected with a permanent establishment or fixed base. Special-relationship adjustments restrict treaty treatment to arm's-length interest amounts. en-us Fri, 18 Oct 2024 12:22:30 +0530 Fri, 18 Oct 2024 12:22:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45351 Article 12 permits both the recipient's State and the source State to tax interest, but limits source withholding when the recipient is the beneficial owner; exemptions apply for interest beneficially owned by governments and the central bank, and additional exemptions may be granted with governmental approval. Interest is defined broadly, penalty charges are excluded, and nexus rules direct taxation to business profits or independent services when interest is effectively connected with a permanent establishment or fixed base. Special-relationship adjustments restrict treaty treatment to arm's-length interest amounts. Act-Rules DTAA Fri, 18 Oct 2024 12:22:30 +0530 https://www.taxtmi.com/acts?id=45351