Query - Interest on debentures

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trilok thadani

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Apr 29, 2012, 5:39:27 AM4/29/12
to ICAI_Pune_Int-Tax
Dear All

Please provide your views:

One of my client has a holding Company located in the United States.
The Holding Company has subscribed for debentures issued by the
subsidiary Company located in India.

The subsidiary Company wants to pay the interest to the Holding
Company.

Whether the provisions of Article 7 or Article 11 should be applied?


Regards
Trilok
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