taxci_en
 

Witholding tax on interest from Jordanie

Last updated: 08-02-2011
Treaty   Jordanie
Article  Interest
Signed   30 October 2006
In force 16 August 2007


1. Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
 
2. However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the beneficial owner of the
    interest is a resident of the other Contracting State, the tax so charged shall not exceed 5 per cent of the gross amount of the interest.

3. Notwithstanding the provisions of paragraph 2, interest arising in one of the Contracting States and paid to a resident of the other Contracting State who is
    the beneficial owner thereof shall be taxable only in that other Contracting State if the payer or the recipient of the interest is the Contracting State itself,
    a statutory body, a political subdivision, or a local authority thereof, or the Central Bank of a Contracting State.

4. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of paragraphs 2 and 3. \

5. The term ‘‘interest’’ as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage, but 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 interest for the purpose of this Article.

6. The provisions of paragraphs 1 and 2 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, or performs in that other State independent
    personal services from a fixed base situated therein and the debt-claim in respect of which the interest is paid is effectively connected with such permanent
    establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply.

7. Interest shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that 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
    or a fixed base in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent
    establishment or fixed base, then such interest shall be deemed to arise in the State in which the permanent establishment or fixed base is situated.

8. 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 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 Jordanie.  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.