Taxation of interest: treaty limits source taxing rights with exemptions for government and public financial institutions. Interest under the DTAA may be taxed in the recipient's residence and also in the State of source but, if the beneficial owner is resident in the other Contracting State, the source State's tax on gross interest is limited to a specified withholding rate. Exemptions apply for interest beneficially owned by Governments, designated public financial institutions, or agreed statutory bodies. Interest is defined broadly as income from debt-claims; deemed source, permanent establishment attribution, and related-party arm's-length adjustments are set out to allocate taxing rights.
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.
Taxation of interest: treaty limits source taxing rights with exemptions for government and public financial institutions.
Interest under the DTAA may be taxed in the recipient's residence and also in the State of source but, if the beneficial owner is resident in the other Contracting State, the source State's tax on gross interest is limited to a specified withholding rate. Exemptions apply for interest beneficially owned by Governments, designated public financial institutions, or agreed statutory bodies. Interest is defined broadly as income from debt-claims; deemed source, permanent establishment attribution, and related-party arm's-length adjustments are set out to allocate taxing rights.
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