Interest taxation under the treaty: source withholding limited to a fixed cap and exemptions for sovereign and export finance institutions. Article 12 allocates taxing rights over interest: interest paid to a resident may be taxed in the resident State, and may also be taxed in the source State subject to a withholding ceiling of 10% where the recipient is the beneficial owner. The Article exempts interest beneficially owned by governments, specified central banks and development agencies, and institutions agreed by competent authorities, and exempts interest connected with loans or credits extended or endorsed by certain export or external trade financing agencies. Definitions, deemed-source rules, permanent establishment connection, and a special-relationship arm's-length adjustment are provided.
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 treaty: source withholding limited to a fixed cap and exemptions for sovereign and export finance institutions.
Article 12 allocates taxing rights over interest: interest paid to a resident may be taxed in the resident State, and may also be taxed in the source State subject to a withholding ceiling of 10% where the recipient is the beneficial owner. The Article exempts interest beneficially owned by governments, specified central banks and development agencies, and institutions agreed by competent authorities, and exempts interest connected with loans or credits extended or endorsed by certain export or external trade financing agencies. Definitions, deemed-source rules, permanent establishment connection, and a special-relationship arm's-length adjustment are provided.
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