Withholding tax on cross-border interest: source taxation allowed but limited, with exemptions for banks and government-backed credits.

Interest may be taxed in the residence State, but the source State may also tax it subject to a source tax limitation when the recipient is the beneficial owner; preferential caps and exemptions apply for bona fide banks, government or central bank recipients, and for interest on credits guaranteed or insured by each State's export credit agencies.

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