https://www.taxtmi.com/acts?id=45451 The treaty permits taxation of interest by the recipient's residence State and also by the source State subject to a withholding tax ceiling when the beneficial owner is resident in the other Contracting State; exemptions apply for interest beneficially owned by the other State's government entities and central bank. is broadly defined to include income from debt-claims and securities while excluding late payment penalties. is deemed to arise where the payer is resident or where a permanent establishment bears the indebtedness; interest connected to a permanent establishment or fixed base of the beneficial owner is taxed under business or independent services provisions. Related-party excess interest is limited to arm's-length amounts for treaty relief, with the excess taxable under domestic law. en-us Fri, 18 Oct 2024 14:38:07 +0530 Fri, 18 Oct 2024 14:38:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45451 The treaty permits taxation of interest by the recipient's residence State and also by the source State subject to a withholding tax ceiling when the beneficial owner is resident in the other Contracting State; exemptions apply for interest beneficially owned by the other State's government entities and central bank. is broadly defined to include income from debt-claims and securities while excluding late payment penalties. is deemed to arise where the payer is resident or where a permanent establishment bears the indebtedness; interest connected to a permanent establishment or fixed base of the beneficial owner is taxed under business or independent services provisions. Related-party excess interest is limited to arm's-length amounts for treaty relief, with the excess taxable under domestic law. Act-Rules DTAA Fri, 18 Oct 2024 14:38:07 +0530 https://www.taxtmi.com/acts?id=45451