taxci_en
 

Withholding tax on interest from Bahrain

Last updated: 08-02-2011
Treaty   Bahrain
Article  Interest
Signed   16 April 2008
In force 24 December 2009

1. Income from debt claims arising in a Contracting State and beneficially owned by a resident of the other Contracting State
    shall be taxable only in that other State.


2. The term 'income from debt claims' 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. Penalty charges for late payment shall not be regarded as income from a debt claim for
    the purpose of this Article.


3. The provisions of paragraph 1 shall not apply if the beneficial owner of the income from a debt claim, being a resident of a
    Contracting State, carries on business in the other Contracting State in which the income from the debt claim arises,
    through a permanent establishment situated therein, and the debt-claim in respect of which the income from the debt
    claim is paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall
    apply.


4. 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 income from a debt claim, 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 Convention.

The above information is the wording of the article dealing with the withholding tax on interest of the tax treaty between The Netherlands and Bahrain.  Please note that the ultimate withholding tax rate may differ from the treaty rate, for instance as consequence of domestic anti-abuse legislation, provisions of the treaty protocol, etc. Before you use this information we therefore strongly recommend that you consult us to determine the accurate withholding tax rate for your specific situation. If you require our follow up, you can contact us via e-mail or call us at our offices: Ph. + 31 (10) 2010466.