Interest withholding tax limited where beneficial owner is resident of other Contracting State; exemptions for governments and central banks. Interest may be taxed in the recipient's State of residence, while the source State may also tax such interest but the tax is limited where the recipient ... Summary
Interest withholding tax limited where beneficial owner is resident of other Contracting State; exemptions for governments and central banks.
Interest may be taxed in the recipient's State of residence, while the source State may also tax such interest but the tax is limited where the recipient is the beneficial owner resident in the other Contracting State and the competent authorities will settle application of that limit. Interest is exempt in the source State when beneficially owned by the Government, political subdivisions or local authorities, or the Central Bank or other mutually agreed governmental banks or financial institutions. Exceptions apply where the interest is effectively connected with a permanent establishment or fixed base, and special-relationship adjustments limit treaty application to the arm's length amount.
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