Interest taxation: residence-based taxation with restricted source-state withholding and specified exemptions for governments, central banks, and export agencies. Interest paid across Contracting States is generally taxable in the recipient's residence but may be taxed at source with a capped withholding when the recipient is the beneficial owner; exemptions cover governmental payers, the central bank, and agreed agencies. Interest tied to loans guaranteed or insured by specified export institutions is taxable only in the creditor's residence. Broad definitions, PE/fixed-base connections shifting treatment to business or service articles, deemed-source rules, and related-party arm's-length adjustments are operative features.
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.
Interest taxation: residence-based taxation with restricted source-state withholding and specified exemptions for governments, central banks, and export agencies.
Interest paid across Contracting States is generally taxable in the recipient's residence but may be taxed at source with a capped withholding when the recipient is the beneficial owner; exemptions cover governmental payers, the central bank, and agreed agencies. Interest tied to loans guaranteed or insured by specified export institutions is taxable only in the creditor's residence. Broad definitions, PE/fixed-base connections shifting treatment to business or service articles, deemed-source rules, and related-party arm's-length adjustments are operative features.
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