Taxation of interest under treaty: payer's residence may tax interest, with source rules for permanent establishments applying. Taxation of interest under the India-United Arab Republic treaty permits the residence state of the payer to tax interest, subject in the United Arab Republic to taxes on income from movable capital and specified withholding taxes and, for natural persons, possible general income tax. Interest is defined broadly to include government securities and all debt-claims; interest is sourced to the payer's residence unless attributable to a permanent establishment, in which case it is sourced to the State of the permanent establishment.
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 under treaty: payer's residence may tax interest, with source rules for permanent establishments applying.
Taxation of interest under the India-United Arab Republic treaty permits the residence state of the payer to tax interest, subject in the United Arab Republic to taxes on income from movable capital and specified withholding taxes and, for natural persons, possible general income tax. Interest is defined broadly to include government securities and all debt-claims; interest is sourced to the payer's residence unless attributable to a permanent establishment, in which case it is sourced to the State of the permanent establishment.
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