https://www.taxtmi.com/acts?id=45384 Interest paid to a resident may be taxed in the recipient's State, but the source State may also tax it subject to limits if the recipient is the beneficial owner. Interest to governments and central banks is exempt in the source State. The Article defines interest as income from debt-claims and excludes penalty charges. Where the beneficial owner has a permanent establishment or fixed base in the source State and the debt is effectively connected with it, business or professional income rules apply. Special-relationship adjustments restrict treaty application to arm's-length amounts. en-us Fri, 18 Oct 2024 12:58:37 +0530 Fri, 18 Oct 2024 12:58:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45384 Interest paid to a resident may be taxed in the recipient's State, but the source State may also tax it subject to limits if the recipient is the beneficial owner. Interest to governments and central banks is exempt in the source State. The Article defines interest as income from debt-claims and excludes penalty charges. Where the beneficial owner has a permanent establishment or fixed base in the source State and the debt is effectively connected with it, business or professional income rules apply. Special-relationship adjustments restrict treaty application to arm's-length amounts. Act-Rules DTAA Fri, 18 Oct 2024 12:58:37 +0530 https://www.taxtmi.com/acts?id=45384