Interest under Albania-India tax treaty: source taxation capped at 10% when paid to the beneficial owner resident. Interest may be taxed by the recipient's State, and the source State may tax such interest but must limit the tax to 10% of gross interest when the beneficial owner is resident in the other Contracting State. Specific exemptions apply where interest is beneficially owned by governments, specified central banks or agreed institutions. Interest is defined as income from debt-claims (excluding penalty charges). Interest is deemed to arise where the payer is resident unless a permanent establishment or fixed base bearing the indebtedness exists; if interest is effectively connected with such presence, provisions for business profits or independent personal services apply. Special-relationship adjustments limit treaty relief to the arm's-length amount.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Interest under Albania-India tax treaty: source taxation capped at 10% when paid to the beneficial owner resident.
Interest may be taxed by the recipient's State, and the source State may tax such interest but must limit the tax to 10% of gross interest when the beneficial owner is resident in the other Contracting State. Specific exemptions apply where interest is beneficially owned by governments, specified central banks or agreed institutions. Interest is defined as income from debt-claims (excluding penalty charges). Interest is deemed to arise where the payer is resident unless a permanent establishment or fixed base bearing the indebtedness exists; if interest is effectively connected with such presence, provisions for business profits or independent personal services apply. Special-relationship adjustments limit treaty relief to the arm's-length amount.
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