https://www.taxtmi.com/acts?id=51324 Article 11 provides that interest may be taxed in the recipient's State and also in the source State, subject to a tax limitation where the beneficial owner is resident in the other State; the competent authorities determine application. Interest is defined as income from debt-claims, excludes penalties, and is excluded from the limitation when effectively connected to a permanent establishment, where Article 7 applies. Deemed-source rules depend on payer residence or permanent establishment bearing the interest, and special-relationship adjustments limit treaty treatment to the arm's length portion. en-us Wed, 21 May 2025 13:19:02 +0530 Thu, 22 May 2025 12:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=51324 Article 11 provides that interest may be taxed in the recipient's State and also in the source State, subject to a tax limitation where the beneficial owner is resident in the other State; the competent authorities determine application. Interest is defined as income from debt-claims, excludes penalties, and is excluded from the limitation when effectively connected to a permanent establishment, where Article 7 applies. Deemed-source rules depend on payer residence or permanent establishment bearing the interest, and special-relationship adjustments limit treaty treatment to the arm's length portion. Act-Rules DTAA Wed, 21 May 2025 13:19:02 +0530 https://www.taxtmi.com/acts?id=51324