https://www.taxtmi.com/acts?id=51407 Interest may be taxed by the residence of the beneficial owner, while the source State may also tax interest but must limit that tax to a negotiated percentage of gross interest when paid to a beneficial owner resident in the other Contracting State; competent authorities determine application. The Article broadly defines interest as income from debt claims, excludes penalty charges, treats interest as arising where the payer or connected permanent establishment/fixed base is resident, and requires arm's-length adjustment where related-party relationships inflate interest. en-us Thu, 22 May 2025 12:01:52 +0530 Tue, 27 May 2025 12:11:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=51407 Interest may be taxed by the residence of the beneficial owner, while the source State may also tax interest but must limit that tax to a negotiated percentage of gross interest when paid to a beneficial owner resident in the other Contracting State; competent authorities determine application. The Article broadly defines interest as income from debt claims, excludes penalty charges, treats interest as arising where the payer or connected permanent establishment/fixed base is resident, and requires arm's-length adjustment where related-party relationships inflate interest. Act-Rules DTAA Thu, 22 May 2025 12:01:52 +0530 https://www.taxtmi.com/acts?id=51407