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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Interest Taxation: Rules for Cross-Border Payments and Permanent Establishments Explained in Article 6.</h1> Interest arising in one Contracting State and paid to a resident of the other Contracting State may be taxed in the state where it originates. However, this does not apply if the interest recipient has a permanent establishment in the state where the interest arises, and the debt-claim is connected to this establishment; in such cases, Article 6 applies. Interest is considered to arise in a state if the payer is the state itself, a political subdivision, local authority, or a resident of that state.
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