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Introducing the βIn Favour Ofβ filter in Case Laws.
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<h1>Taxation of Interest Under Article 11 of DTAA: Max 10% Rate, Exemptions for Government-Linked Interest Apply</h1> Article 11 of the Double Taxation Avoidance Agreement (DTAA) between Ireland and another Contracting State addresses the taxation of interest. Interest paid to a resident of one Contracting State by another may be taxed in the recipient's state but can also be taxed where it arises, with a maximum tax rate of 10% if the recipient is the beneficial owner. Certain exemptions apply, such as interest linked to government or specified financial institutions. The article defines 'interest' and outlines exceptions where interest is connected to a permanent establishment. It also addresses situations involving special relationships affecting interest amounts.