Interest taxation limits: source state withholding permitted but capped; government recipients exempt under treaty. Article 12 permits taxation of interest in the recipient's State while allowing the source State to tax such interest subject to a statutory cap; interest paid to the other State's government, local authorities, central bank or wholly owned agencies is exempt in the source State by agreement of the competent authorities. The Article defines interest to include government securities, bonds, debentures and other debt claims and provides that where the recipient has a permanent establishment or fixed base to which the debt is effectively connected, business profits or independent personal services rules apply; related party excess interest is limited to an 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.
Interest taxation limits: source state withholding permitted but capped; government recipients exempt under treaty.
Article 12 permits taxation of interest in the recipient's State while allowing the source State to tax such interest subject to a statutory cap; interest paid to the other State's government, local authorities, central bank or wholly owned agencies is exempt in the source State by agreement of the competent authorities. The Article defines interest to include government securities, bonds, debentures and other debt claims and provides that where the recipient has a permanent establishment or fixed base to which the debt is effectively connected, business profits or independent personal services rules apply; related party excess interest is limited to an arm's length amount.
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