https://www.taxtmi.com/acts?id=51357 Article 11 provides that interest arising in one Contracting State and beneficially owned by a resident of the other is taxable only in the resident State, subject to enumerated exceptions allowing source-state taxation (including connected party, contingent, special regime, expatriated entity and notional deduction situations), reduced treaty withholding in limited Limitation on Benefits cases, a definition of interest covering all debt-claim income, a permanent establishment recharacterisation rule for interest borne by or allocable to a PE or certain profits, and an arm's length adjustment where related party arrangements inflate interest. en-us Wed, 21 May 2025 15:38:37 +0530 Wed, 21 May 2025 15:38:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=51357 Article 11 provides that interest arising in one Contracting State and beneficially owned by a resident of the other is taxable only in the resident State, subject to enumerated exceptions allowing source-state taxation (including connected party, contingent, special regime, expatriated entity and notional deduction situations), reduced treaty withholding in limited Limitation on Benefits cases, a definition of interest covering all debt-claim income, a permanent establishment recharacterisation rule for interest borne by or allocable to a PE or certain profits, and an arm's length adjustment where related party arrangements inflate interest. Act-Rules DTAA Wed, 21 May 2025 15:38:37 +0530 https://www.taxtmi.com/acts?id=51357