Interest taxation: source-state withholding limited where recipient is beneficial owner; exemptions for public institutions apply. Interest arising in a Contracting State may be taxed in the recipient's State, and may also be taxed in the State of source but, if the recipient is the beneficial owner, source-state tax shall not exceed 10 per cent of the gross interest. Exemptions apply where specified public and financial institutions beneficially own the interest, and alternative rules apply when the interest is effectively connected to a permanent establishment or fixed base.
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 limited where recipient is beneficial owner; exemptions for public institutions apply.
Interest arising in a Contracting State may be taxed in the recipient's State, and may also be taxed in the State of source but, if the recipient is the beneficial owner, source-state tax shall not exceed 10 per cent of the gross interest. Exemptions apply where specified public and financial institutions beneficially own the interest, and alternative rules apply when the interest is effectively connected to a permanent establishment or fixed base.
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