Introducing the “In Favour Of” filter in Case Laws.
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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Interest Taxable in Recipient's State; Capped at 10% in Origin State if Beneficial Owner is Resident.</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's state but can also be taxed in the state of origin, with a cap of 10% if the beneficial owner is a resident of the other state. Exemptions apply for interest beneficially owned by government entities or specific financial institutions. The term 'interest' covers income from debt-claims but excludes dividends and penalty charges. Provisions do not apply if the interest is connected to a business or service conducted through a permanent establishment. Interest is deemed to arise in the payer's state unless linked to a permanent establishment elsewhere. Special relationships affecting interest amounts are subject to standard taxation laws.
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