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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Interest Taxation Rules in Cross-Border Transactions: Maximum 10% Tax, Government Exceptions, Special Relationship Considerations</h1> Interest arising in one Contracting State and paid to a resident of the other Contracting State may be taxed in the recipient's State but can also be taxed in the State where it arises, with a maximum tax of 10% if the beneficial owner resides in the other State. Exceptions include interest paid to government-related entities, which is taxable only in the recipient's State. Interest is defined broadly, excluding penalty charges for late payment. The provisions do not apply if the interest is connected to a permanent establishment or fixed base. Interest is deemed to arise where the payer is a resident unless linked to a permanent establishment. Special relationships affecting interest amounts are subject to separate taxation rules.
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