Interest taxation: source-state withholding capped where recipient is beneficial owner, with specified exemptions and PE carve-outs. Interest paid to a resident of the other Contracting State may be taxed in that resident's State, but the source State may also tax such interest with a withholding limit of ten percent for the beneficial owner; exemptions apply for the other State, its subdivisions, the Central Bank and wholly owned agencies, and for other residents when the source State's Government approves the transaction. Interest connected with a permanent establishment or fixed base is taxed under business profits or independent services rules, and related-party excess interest is limited to an arm's-length amount.
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: source-state withholding capped where recipient is beneficial owner, with specified exemptions and PE carve-outs.
Interest paid to a resident of the other Contracting State may be taxed in that resident's State, but the source State may also tax such interest with a withholding limit of ten percent for the beneficial owner; exemptions apply for the other State, its subdivisions, the Central Bank and wholly owned agencies, and for other residents when the source State's Government approves the transaction. Interest connected with a permanent establishment or fixed base is taxed under business profits or independent services rules, and related-party excess interest is limited to an arm's-length amount.
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