Cross-border interest taxation: source withholding limited for beneficial owners, with exemptions for government and central bank recipients. Cross-border interest may be taxed in the recipient's residence, while the source State may tax interest but, if the recipient is the beneficial owner, source withholding is limited and its application coordinated by the competent authorities. Interest is exempt at source where beneficially owned by government entities or specified central banking and agreed governmental financial institutions. The Article broadly defines interest as income from debt-claims excluding penalties, attributes source by payer or by connection to a permanent establishment or fixed base, and confines treaty relief where related-party arrangements produce non-arm's-length interest.
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.
Cross-border interest taxation: source withholding limited for beneficial owners, with exemptions for government and central bank recipients.
Cross-border interest may be taxed in the recipient's residence, while the source State may tax interest but, if the recipient is the beneficial owner, source withholding is limited and its application coordinated by the competent authorities. Interest is exempt at source where beneficially owned by government entities or specified central banking and agreed governmental financial institutions. The Article broadly defines interest as income from debt-claims excluding penalties, attributes source by payer or by connection to a permanent establishment or fixed base, and confines treaty relief where related-party arrangements produce non-arm's-length interest.
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