Withholding tax on interest: capped for beneficial owners and exempt for specified public financial recipients. Interest arising in a Contracting State and paid to a resident of the other State may be taxed in the recipient's State, but the source State may also tax such interest; if the recipient is the beneficial owner the tax so charged shall not exceed 10 per cent of the gross amount. Interest is exempt in the source State when beneficially owned by the Government, political subdivisions, local authorities, the Central Bank, or mutually agreed banks or governmental financial institutions. Interest connected to a permanent establishment or fixed base is deemed to arise where that establishment or base is situated, and special-relationship excess interest is taxable under domestic law.
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.
Withholding tax on interest: capped for beneficial owners and exempt for specified public financial recipients.
Interest arising in a Contracting State and paid to a resident of the other State may be taxed in the recipient's State, but the source State may also tax such interest; if the recipient is the beneficial owner the tax so charged shall not exceed 10 per cent of the gross amount. Interest is exempt in the source State when beneficially owned by the Government, political subdivisions, local authorities, the Central Bank, or mutually agreed banks or governmental financial institutions. Interest connected to a permanent establishment or fixed base is deemed to arise where that establishment or base is situated, and special-relationship excess interest is taxable under domestic law.
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