Interest withholding tax cap on cross-border payments: reduced taxation where the recipient is the beneficial owner of the interest. Interest paid to a resident of the other Contracting State may be taxed in the recipient's State; the source State may also tax such interest but limits its tax where the recipient is the beneficial owner. Exemptions from source taxation include specified governments, designated public banks and the national bank, and other institutions agreed by Competent Authorities. Interest tied to a permanent establishment or fixed base is taxed under business profits or independent personal services rules, and amounts exceeding arm's-length interest remain taxable under domestic law.
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 withholding tax cap on cross-border payments: reduced taxation where the recipient is the beneficial owner of the interest.
Interest paid to a resident of the other Contracting State may be taxed in the recipient's State; the source State may also tax such interest but limits its tax where the recipient is the beneficial owner. Exemptions from source taxation include specified governments, designated public banks and the national bank, and other institutions agreed by Competent Authorities. Interest tied to a permanent establishment or fixed base is taxed under business profits or independent personal services rules, and amounts exceeding arm's-length interest remain taxable under domestic law.
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