https://www.taxtmi.com/acts?id=45609 Interest arising in one Contracting State and paid to a resident of the other may be taxed by the residence State, while the source State may also tax the interest subject to a treaty limit when the beneficial owner is resident in the other State. The Article defines interest broadly as income from debt-claims and excludes amounts treated as dividends under Article 10. Interest effectively connected with a permanent establishment or fixed base is taxed under the rules for business profits or independent personal services, and where a special relationship inflates interest, treaty relief applies only to the arm's length portion. en-us Fri, 18 Oct 2024 18:15:36 +0530 Wed, 23 Oct 2024 16:11:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45609 Interest arising in one Contracting State and paid to a resident of the other may be taxed by the residence State, while the source State may also tax the interest subject to a treaty limit when the beneficial owner is resident in the other State. The Article defines interest broadly as income from debt-claims and excludes amounts treated as dividends under Article 10. Interest effectively connected with a permanent establishment or fixed base is taxed under the rules for business profits or independent personal services, and where a special relationship inflates interest, treaty relief applies only to the arm's length portion. Act-Rules DTAA Fri, 18 Oct 2024 18:15:36 +0530 https://www.taxtmi.com/acts?id=45609