Interest taxation under the DTAA: source-state taxing rights, reduced withholding rates, exemptions, and permanent establishment carve-outs. Interest arising in one Contracting State and paid to a resident of the other Contracting State may be taxed in that other State, while the source State may also tax it subject to a cap of 10 per cent for bank loans used for equipment or investment projects and 15 per cent in other cases. Interest paid to specified government entities is exempt in the source State, and interest from government-issued securities is taxable only in the issuing State. The article also defines interest, provides source rules, excludes effectively connected income, and limits treaty relief to arm's-length amounts where a special relationship exists.
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Provisions expressly mentioned in the judgment/order text.
Interest taxation under the DTAA: source-state taxing rights, reduced withholding rates, exemptions, and permanent establishment carve-outs.
Interest arising in one Contracting State and paid to a resident of the other Contracting State may be taxed in that other State, while the source State may also tax it subject to a cap of 10 per cent for bank loans used for equipment or investment projects and 15 per cent in other cases. Interest paid to specified government entities is exempt in the source State, and interest from government-issued securities is taxable only in the issuing State. The article also defines interest, provides source rules, excludes effectively connected income, and limits treaty relief to arm's-length amounts where a special relationship exists.
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