Interest taxation: source-state tax on cross-border interest payments capped when paid to non-resident beneficial owners.

Interest arising in one Contracting State paid to a resident of the other may be taxed in the recipient's State, but the source State may also tax such interest subject to a reduced withholding limit when the beneficial owner is resident of the other State. Exemptions allocate exclusive rights where interest is paid to specified government bodies or public financial institutions, and loans guaranteed by such bodies are taxable only in the recipient State. Connection to a permanent establishment or fixed base makes the interest taxable under business profits or independent services rules. Interest is deemed to arise where the payer resides unless a permanent establishment or fixed base bears the indebtedness. Related-party excess interest is limited to arm's-length amounts.

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