Taxation of interest: source taxation limited when recipient is beneficial owner; exemptions for governments and specified institutions. Article 11 provides that interest or gains arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State, while the source State may also tax such income subject to a limitation when the recipient is the beneficial owner. Exemptions from source taxation apply for governments, specified financial institutions and other agreed entities. Income connected with a permanent establishment or fixed base is taxed under the business or independent personal services provisions, and amounts inflated by special relationships are limited to the arm's length amount.
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 interest: source taxation limited when recipient is beneficial owner; exemptions for governments and specified institutions.
Article 11 provides that interest or gains arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State, while the source State may also tax such income subject to a limitation when the recipient is the beneficial owner. Exemptions from source taxation apply for governments, specified financial institutions and other agreed entities. Income connected with a permanent establishment or fixed base is taxed under the business or independent personal services provisions, and amounts inflated by special relationships are limited to the arm's length amount.
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