taxci_en
 

Witholding tax on Interest from Qatar

Last updated: 09-02-2011
Treaty   Qatar
Article  Interest
Signed   24 April 2008
In force 25 December 2009


1. Interest 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 '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. Penalty charges for late payment shall not be regarded as interest for the purpose of this  
     Article.

3. The provisions of paragraph 1 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 the 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.

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
    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.

The above information is the wording of the article dealing with the withholding tax on interest of the tax treaty between The Netherlands and Qatar.  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.