Interest on cross-border debt can be taxed at source but is capped at 10% when paid to the beneficial owner. Interest paid to a resident of the other Contracting State may be taxed in the recipient's State, but the source State may also tax such interest and, where the recipient is the beneficial owner, tax on the gross amount of interest shall not exceed 10 per cent; special rules treat interest as arising where the payer is resident or where a PE or fixed base bears the indebtedness.
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 on cross-border debt can be taxed at source but is capped at 10% when paid to the beneficial owner.
Interest paid to a resident of the other Contracting State may be taxed in the recipient's State, but the source State may also tax such interest and, where the recipient is the beneficial owner, tax on the gross amount of interest shall not exceed 10 per cent; special rules treat interest as arising where the payer is resident or where a PE or fixed base bears the indebtedness.
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