https://www.taxtmi.com/acts?id=45641 Article 12 allocates taxing rights on interest: interest paid to a resident may be taxed in the recipient's State, while the source State may also tax it subject to a reduced treaty rate when the recipient is the beneficial owner. Specific exemptions apply for interest beneficially owned by governments, designated central banking or public development institutions, and for interest connected with loans or credits backed by specified public export finance institutions. Interest connected to a permanent establishment or fixed base is taxed as business or service income, and special relationship adjustments limit treaty application to arm's length interest. en-us Wed, 23 Oct 2024 12:32:24 +0530 Wed, 23 Oct 2024 13:08:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45641 Article 12 allocates taxing rights on interest: interest paid to a resident may be taxed in the recipient's State, while the source State may also tax it subject to a reduced treaty rate when the recipient is the beneficial owner. Specific exemptions apply for interest beneficially owned by governments, designated central banking or public development institutions, and for interest connected with loans or credits backed by specified public export finance institutions. Interest connected to a permanent establishment or fixed base is taxed as business or service income, and special relationship adjustments limit treaty application to arm's length interest. Act-Rules DTAA Wed, 23 Oct 2024 12:32:24 +0530 https://www.taxtmi.com/acts?id=45641