Interest withholding limits: treaty caps source-state taxation where the beneficial owner is resident, with exemptions for governments and central banks.

Article 11 permits taxation of interest in the recipient's State while allowing the source State to tax interest arising there, subject to a limitation where the beneficial owner is resident of the other Contracting State (the tax charged shall not exceed 10 per cent of the gross amount). Exemptions apply for interest beneficially owned by governments or central banks. Interest is defined as income from debt-claims; special rules treat interest as arising where the payer is resident or where a permanent establishment or fixed base bears the indebtedness, and arm's-length adjustments apply where related-party relationships inflate interest.

---

---

---