Introducing the “In Favour Of” filter in Case Laws.
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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Interest Taxed in Both States Capped at 10% for Residents; Exemptions for Government and Financial Institutions</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in both States, but the tax in the source State shall not exceed 10% if the beneficial owner is a resident of the other State. Exemptions apply if the interest is derived by certain governmental and financial institutions. 'Interest' includes income from debt-claims, government securities, bonds, and debentures, excluding penalty charges for late payment. Provisions do not apply if the interest is connected to a permanent establishment or fixed base. Interest is deemed to arise where the payer is resident or where a permanent establishment is situated. Special relationships affecting interest amounts are subject to specific provisions.
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