その他令和8年7月1日
租税条約における利息およびロイヤルティに関する規定
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ARTICLE 11
INTEREST
1. Interest arising in a Contracting State and paid to a resident of the other
Contracting State may be taxed in that other Contracting State.
2. However, interest arising in a Contracting State may also be taxed in that
Contracting State according to the laws of that Contracting State, but if the beneficial
owner of the interest is a resident of the other Contracting State, the tax so charged shall
not exceed 8 per cent of the gross amount of the interest.
3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting
State shall be taxable only in the other Contracting State if:
(a) is beneficially owneficially owned by that other Contracting State, a
political or administrative subdivision or local authority thereof, the
central bank of that other Contracting State or any institution wholly
owned by that other Contracting State or a political or administrative
subdivision or local authority thereof;
(b) the interest is beneficially owned by a resident of that other Contracting
State with respect to debt-claims guaranteed, insured or indirectly financed
by that other Contracting State, a political or administrative subdivision or
local authority thereof, the central bank of that other Contracting State or
any institution wholly owned by that other Contracting State or a political
or administrative subdivision or local authority thereof; or
(c) the interest is beneficially owned by a resident of that other Contracting
State and paid with respect to debt-claims arising as a part of the sale of
equipment or merchandise, or the provision of services, on credit by a
resident of that other Contracting State
4. The term "interest" as used in this Article means income from debt-claims of
every kind, whether or not secured by mortgage and whether or not carrying a right to
participate in the debtor's profits, and in particular, income from government securities
and income from bonds or debentures, including premiums and prizes attaching to such
securities, bonds or debentures as well as other income that is subjected to the same
taxation treatment as income from money lent by the laws of the Contracting State in
which the income arises. Income dealt with in Article 10 and penalty charges for late
payment shall not be regarded as interest for the purposes of this Article
5. The provisions of paragraphs 1,2 and 3 shall not apply if the beneficial owner of
the interest, being a resident of a Contracting State, carries on business in the other
Contracting State in which the interest arises through a permanent establishment situated
therein and the debt-claim in respect of which the interest is paid is effectively connected
with such permanent establishment. In such case the provisions of Article 7 shall apply
6. Interest shall be deemed to arise in a Contracting State when the payer is a resident
of that Contracting State. Where, however, the person paying the interest, whether he
is a resident of a Contracting State or not, has in a Contracting State a permanent
establishment in connection with which the indebtedness on which the interest is paid
was incurred, and such interest is borne by such permanent establishment, then such
interest shall be deemed to arise in the Contracting State in which the permanent
establishment is situated.
.1
. Where, by reason of a special relationship between the payer and the beneficial
owner or between both of them and some other person, the amount of the interest, having
regard to the debt-claim for which it is paid, exceeds the amount which would have been
agreed upon by the payer and the beneficial owner in the absence of such relationship.
the provisions of this Article shall apply only to the last-mentioned amount. In such
case, the excess part of the payments shall remain taxable according to the laws of each
Contracting State, due regard being had to the other provisions of this Agreement.
ARTICLE 12
ROYALTIES
. Royalties arising in a Contracting State and paid to a resident of the other
Contracting State may be taxed in that other Contracting State
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