Taxation of cross-border interest: source taxation limited where recipient is beneficial owner, with government exemptions. Interest paid to a resident may be taxed in the recipient's State, and may also be taxed in the source State but, where the recipient is the beneficial owner, source tax shall not exceed ten percent of the gross interest; the competent authorities shall agree the mode of application. Government-derived interest and interest on government-guaranteed loans are exempt in the source State. Exceptions apply where interest is effectively connected with a permanent establishment or fixed base, and an arm's-length rule adjusts amounts where special relationships 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.
Taxation of cross-border interest: source taxation limited where recipient is beneficial owner, with government exemptions.
Interest paid to a resident may be taxed in the recipient's State, and may also be taxed in the source State but, where the recipient is the beneficial owner, source tax shall not exceed ten percent of the gross interest; the competent authorities shall agree the mode of application. Government-derived interest and interest on government-guaranteed loans are exempt in the source State. Exceptions apply where interest is effectively connected with a permanent establishment or fixed base, and an arm's-length rule adjusts amounts where special relationships inflate interest.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
