Limited withholding tax on cross-border interest: source taxation allowed subject to a reduced rate for resident beneficial owners. Interest paid to a resident of the other Contracting State may be taxed in the recipient's State, but the source State may tax such interest subject to a withholding tax not exceeding 10 per cent of the gross amount where the beneficial owner is a resident of the other State. Exemptions from source taxation apply for interest beneficially owned by or connected with loans extended or endorsed by specified governmental or public financial institutions or other institutions agreed by the competent authorities. The Article defines 'interest,' addresses permanent establishment connections that shift taxation to business profit or service provisions, sets deeming rules for source, and requires arm's-length adjustment where special relationships affect interest amounts.
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.
Limited withholding tax on cross-border interest: source taxation allowed subject to a reduced rate for resident beneficial owners.
Interest paid to a resident of the other Contracting State may be taxed in the recipient's State, but the source State may tax such interest subject to a withholding tax not exceeding 10 per cent of the gross amount where the beneficial owner is a resident of the other State. Exemptions from source taxation apply for interest beneficially owned by or connected with loans extended or endorsed by specified governmental or public financial institutions or other institutions agreed by the competent authorities. The Article defines "interest," addresses permanent establishment connections that shift taxation to business profit or service provisions, sets deeming rules for source, and requires arm's-length adjustment where special relationships affect interest amounts.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
