Interest taxation limited to residence state, with specified source state exceptions and withholding where connected or contingent interests arise. Article 11 provides that interest arising in one Contracting State and beneficially owned by a resident of the other is taxable only in the resident State, subject to enumerated exceptions allowing source-state taxation (including connected party, contingent, special regime, expatriated entity and notional deduction situations), reduced treaty withholding in limited Limitation on Benefits cases, a definition of interest covering all debt-claim income, a permanent establishment recharacterisation rule for interest borne by or allocable to a PE or certain profits, and an arm's length adjustment where related party arrangements inflate interest.
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 limited to residence state, with specified source state exceptions and withholding where connected or contingent interests arise.
Article 11 provides that interest arising in one Contracting State and beneficially owned by a resident of the other is taxable only in the resident State, subject to enumerated exceptions allowing source-state taxation (including connected party, contingent, special regime, expatriated entity and notional deduction situations), reduced treaty withholding in limited Limitation on Benefits cases, a definition of interest covering all debt-claim income, a permanent establishment recharacterisation rule for interest borne by or allocable to a PE or certain profits, and an arm's length adjustment where related party arrangements inflate interest.
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