Interest taxation: source-state withholding is limited when the beneficial owner is resident in the other Contracting State. Article 11 permits taxation of interest in the residence State but allows source-State taxation subject to a limited withholding where the beneficial ... Summary
Interest taxation: source-state withholding is limited when the beneficial owner is resident in the other Contracting State.
Article 11 permits taxation of interest in the residence State but allows source-State taxation subject to a limited withholding where the beneficial owner is resident in the other Contracting State; exemptions apply for governments, specified national financial institutions and other agreed institutions. Interest is defined as income from debt claims (excluding penalty charges). Interest effectively connected with a permanent establishment or fixed base is taxed under the provisions for business profits or independent personal services. Related party excess interest is limited to an arm's-length amount, with the surplus taxable under domestic law.
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