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 ... Summary
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.
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