Interest taxation limited by treaty with source-state withholding capped for beneficial owners and specified institutional exemptions. Interest paid to a resident of the other Contracting State may be taxed in that resident State, but the State of source may also tax such interest subject to a treaty limitation where the recipient is the beneficial owner. Exemptions are provided for interest derived by or connected with loans or credits from specified public or agreed institutions. The withholding limitation does not apply where the beneficial owner has a permanent establishment or fixed base in the source State and the debt-claim is effectively connected; in that case business- or service related provisions govern. Interest is deemed to arise where the payer is resident unless attributable to a permanent establishment or fixed base.
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.
Interest taxation limited by treaty with source-state withholding capped for beneficial owners and specified institutional exemptions.
Interest paid to a resident of the other Contracting State may be taxed in that resident State, but the State of source may also tax such interest subject to a treaty limitation where the recipient is the beneficial owner. Exemptions are provided for interest derived by or connected with loans or credits from specified public or agreed institutions. The withholding limitation does not apply where the beneficial owner has a permanent establishment or fixed base in the source State and the debt-claim is effectively connected; in that case business- or service related provisions govern. Interest is deemed to arise where the payer is resident unless attributable to a permanent establishment or fixed base.
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