Introducing the “In Favour Of” filter in Case Laws.
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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Interest Taxed in Both States; Capped at 10% if Beneficial Owner. Exempt for Governments, Central Banks.</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in both states, but if the recipient is the beneficial owner, the tax in the state of origin is capped at 10%. Interest is exempt if derived by the government, central bank, or specified financial institutions. 'Interest' covers income from debt-claims, excluding penalties for late payment. Provisions don't apply if the interest is effectively connected to a permanent establishment in the state of origin. Interest is deemed to arise where the payer is based, with special rules for excess interest due to relationships.
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