Taxation of interest: source taxation limited with exemptions for governments and PE-connected interest taxed as business income. Interest arising in one Contracting State and paid to a resident of the other may be taxed in both States, but source taxation is limited for the beneficial owner and the competent authorities shall determine application. Interest paid to the other State's government, central bank, or agreed governmental financial institutions is exempt in the source State. Interest connected to a permanent establishment or fixed base is treated as arising where that establishment or base is situated, and if so connected Articles on business profits or independent personal services apply. Amounts above arm's-length interest due to special relationships remain taxable under domestic law.
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.
Taxation of interest: source taxation limited with exemptions for governments and PE-connected interest taxed as business income.
Interest arising in one Contracting State and paid to a resident of the other may be taxed in both States, but source taxation is limited for the beneficial owner and the competent authorities shall determine application. Interest paid to the other State's government, central bank, or agreed governmental financial institutions is exempt in the source State. Interest connected to a permanent establishment or fixed base is treated as arising where that establishment or base is situated, and if so connected Articles on business profits or independent personal services apply. Amounts above arm's-length interest due to special relationships remain taxable under domestic law.
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