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of <h1>Interest Taxation Rules in NZ Double Taxation Agreement: 10% Cap, Exemptions for Government Entities, Special Relationship Clauses Apply</h1> Article 11 of the Double Taxation Avoidance Agreement (DTAA) between New Zealand and another Contracting State addresses the taxation of interest. Interest paid to a resident of one Contracting State by another may be taxed in the recipient's State but can also be taxed in the State where it arises, capped at 10% if the recipient is the beneficial owner. Exemptions apply for interest beneficially owned by governmental or certain financial institutions. The article defines 'interest' broadly but excludes penalties for late payment. Provisions do not apply if the interest is connected to a permanent establishment or fixed base in the other State. Special relationships affecting interest amounts may alter tax obligations.
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