Withholding tax on cross-border interest: source taxation allowed but limited, with exemptions for banks and government-backed credits. Interest may be taxed in the residence State, but the source State may also tax it subject to a source tax limitation when the recipient is the beneficial owner; preferential caps and exemptions apply for bona fide banks, government or central bank recipients, and for interest on credits guaranteed or insured by each State's export credit agencies.
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.
Withholding tax on cross-border interest: source taxation allowed but limited, with exemptions for banks and government-backed credits.
Interest may be taxed in the residence State, but the source State may also tax it subject to a source tax limitation when the recipient is the beneficial owner; preferential caps and exemptions apply for bona fide banks, government or central bank recipients, and for interest on credits guaranteed or insured by each State's export credit agencies.
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