Double Taxation Agreement

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INTEREST
ARTICLE 11:

62	Scope.
63.	Taxability of interest.
63.1	Arising or deemed arising of income.
63.1-1	Deemed arising.
63.2	Arising of income.
63.3	Arising of income of Pakistan.
63.4	Arising of income in a country where elements of contracts are most densely grouped.
63.5	Rates of withholding tax of agreements.
64.	Interest - Definition of.
64.1	Debt-claims of every kind.
64.2	Debt-Meaning of.
64.3	Debt is a chose-in-action, a property.
64.4	Amount paid as compensation or damages is not interest.
64.5	Unpaid purchase money.
64.6	Amount received in exercise of a right severed from principal debt is not interest.
64.7	Amount of discount.
64.8	Amount paid as interest by a thinly capitalised corporation is not taken interest but is deemed dividend.
64.9	Debt even if secured by mortgage may yield interest.
64.10	Interest on bonds and debentures.
64.11	Premium and prizes attached to securities, bonds and debentures is interest.
64.12	Penalty is not interest.
65.	Debt-claim which forms part of permanent establishment is not interest but business income.
66.	Paragraph 5 and the fiction about arising of income.
67.	Interest and the doctrine of arm’s length.