Interest taxation under the Cyprus DTAA restricts source taxation for beneficial owners while providing exemptions and PE exceptions. Article 11 allocates primary taxing rights on interest to the recipient's residence while allowing source taxation subject to a reduced withholding where the recipient is the beneficial owner; exemptions apply for interest beneficially owned by the other Contracting State, its subdivisions, the other State's central bank or wholly owned agencies, and potentially other residents with Government approval. Interest is defined as income from debt-claims excluding penalty charges.
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 under the Cyprus DTAA restricts source taxation for beneficial owners while providing exemptions and PE exceptions.
Article 11 allocates primary taxing rights on interest to the recipient's residence while allowing source taxation subject to a reduced withholding where the recipient is the beneficial owner; exemptions apply for interest beneficially owned by the other Contracting State, its subdivisions, the other State's central bank or wholly owned agencies, and potentially other residents with Government approval. Interest is defined as income from debt-claims excluding penalty charges.
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