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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Taxation of Interest Under DTAA Article 11: 10% Cap, Exemptions for Government Entities and Central Banks</h1> Article 11 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of interest. Interest paid to a resident of one Contracting State by the other may be taxed in the recipient's state, but also in the state where it arises, with a tax cap of 10% if the recipient is the beneficial owner. Exemptions apply for interest beneficially owned by government entities or central banks, and potentially other approved residents. Interest is defined broadly, excluding penalty charges. Exceptions apply if the interest is connected to a permanent establishment or fixed base. Special relationships affecting interest amounts may alter applicable provisions.
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