Cross-border interest tax limitation where recipient is beneficial owner; bank and government exemptions; PE-linked interest treated under business rules. Article 12 limits source-state taxation of interest paid to a resident beneficial owner, subject to reduced withholding for qualifying recipients and ... Summary
Cross-border interest tax limitation where recipient is beneficial owner; bank and government exemptions; PE-linked interest treated under business rules.
Article 12 limits source-state taxation of interest paid to a resident beneficial owner, subject to reduced withholding for qualifying recipients and special relief for banks and government entities. Interest deemed to be connected with a permanent establishment or fixed base is taxed under business profits or independent personal services rules, and related-party excess payments are restricted to arm's length amounts.
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