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of <h1>Article 11 of DTAA Limits Cross-Border Interest Tax to 10%, Exemptions for Government and Central Banks</h1> Article 11 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of interest. Interest paid from one State to a resident of the other may be taxed in the recipient's State, but also in the State where it arises, with a maximum tax rate of 10% if the beneficial owner resides in the other State. Exemptions apply if the interest is derived by governmental or central banking institutions. The term 'interest' covers income from various debt-claims, excluding penalty charges. Specific provisions apply if the interest is linked to a permanent establishment or fixed base. Special relationships affecting interest amounts are subject to standard taxation rules.
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