Introducing the “In Favour Of” filter in Case Laws.
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Introducing the “In Favour Of” filter in Case Laws.
Try it now in Case Laws →
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of <h1>Interest Taxed in Both States, Capped at 10% for Cross-Border Payments; Exceptions for Government Entities Apply.</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's state, but also in the state where it arises, capped at 10% if the beneficial owner resides in the other state. Exceptions allow exclusive taxation in the recipient's state if paid to certain government or state-owned entities. Interest from loans guaranteed by these entities is taxed only in the recipient's state. The term 'interest' excludes penalty charges for late payment. Provisions do not apply if the interest is connected to a permanent establishment or fixed base. Special relationships affecting interest amounts are subject to specific taxation rules.
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