Taxation of interest: source State may tax but tax on beneficial owner limited; government and guaranteed-loan interest exempt. Primary taxing rights over interest are allocated to the recipient's State while the source State may tax interest paid to a beneficial owner subject to a ... Summary
Taxation of interest: source State may tax but tax on beneficial owner limited; government and guaranteed-loan interest exempt.
Primary taxing rights over interest are allocated to the recipient's State while the source State may tax interest paid to a beneficial owner subject to a limitation; governments and government-guaranteed loan interest are exempt. The Article defines interest as income from debt-claims (excluding penalty charges) and includes examples. Interest connected to a permanent establishment or fixed base is taxed where that establishment or base is situated, and where related-party relationships inflate interest, only the arm's-length amount falls under the Article, the excess remaining taxable under domestic law.
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