Taxation of interest: source state may tax interest unless effectively connected to a permanent establishment. Interest arising in a Contracting State may be taxed in the State of source, except where the resident recipient's debt-claim is effectively connected with a permanent establishment in that source State, in which case the provisions on business profits and source attribution apply; interest is deemed to arise where the payer is the State, a political subdivision, a local authority or a resident.
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 state may tax interest unless effectively connected to a permanent establishment.
Interest arising in a Contracting State may be taxed in the State of source, except where the resident recipient's debt-claim is effectively connected with a permanent establishment in that source State, in which case the provisions on business profits and source attribution apply; interest is deemed to arise where the payer is the State, a political subdivision, a local authority or a resident.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
