https://www.taxtmi.com/acts?id=45483 Article 11 permits source state taxation of interest paid to a resident of the other Contracting State but limits that source tax where the recipient is the beneficial owner; it defines interest broadly, treats interest as arising where the payer or an affected permanent establishment is situated, provides that connection to a permanent establishment negates withholding relief in favour of business income rules, allows related party adjustments to arm's length amounts, includes an anti abuse principal purpose provision, and exempts interest beneficially owned by foreign governments and central banks. en-us Fri, 18 Oct 2024 15:03:00 +0530 Fri, 18 Oct 2024 15:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45483 Article 11 permits source state taxation of interest paid to a resident of the other Contracting State but limits that source tax where the recipient is the beneficial owner; it defines interest broadly, treats interest as arising where the payer or an affected permanent establishment is situated, provides that connection to a permanent establishment negates withholding relief in favour of business income rules, allows related party adjustments to arm's length amounts, includes an anti abuse principal purpose provision, and exempts interest beneficially owned by foreign governments and central banks. Act-Rules DTAA Fri, 18 Oct 2024 15:03:00 +0530 https://www.taxtmi.com/acts?id=45483