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of <h1>Article 11 of Austria's DTAA: Taxation Rules for Interest, Including Exemptions and Special Relationship Conditions</h1> Article 11 of the Double Tax Avoidance Agreement (DTAA) between Austria and another Contracting State addresses the taxation of interest. Interest paid to a resident of one Contracting State by the other may be taxed in the recipient's state, but also in the state where it originates, with a maximum tax rate of 10% if the recipient is the beneficial owner. Exemptions from tax apply for interest beneficially owned by government entities, central banks, and certain approved entities. Interest is defined as income from debt claims, excluding penalties for late payment. The article also outlines conditions under which the provisions do not apply, such as when the interest is connected to a permanent establishment. It also addresses interest payments influenced by special relationships, limiting the taxable amount to what would be agreed in an arm's length transaction.
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