background image
CHAPTER I - Income Tax
CHAPTER II - Registration Fees and Stamp Duties
Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 18

[Interest]

(1) Tax on income from loans, deposits, deposit accounts, certificates of deposit and any other debt claims not represented by negotiable securities, shall be taxed in the State of the fiscal domicile of the creditor.

(2) However, each Contracting State shall reserve the right to tax, by way of withholding at source, the income referred to under paragraph (1) of this Article above, if allowed under its domestic laws.

(3) The provisions of the above-mentioned paragraphs (1) and (2) of this Convention shall not apply where the beneficial owner of the interest, domiciled in a Contracting State, has in the other Contracting State, from where the interest arises, a permanent establishment to which the debt claim which produces it is effectively attached. In such case, Article 10 of this Convention concerning attribution of profits to permanent establishments shall be applicable.