Interest withholding limits for cross-border payments reduced under treaty, with exemptions for specified government and central bank creditors. The treaty allows recipient-State taxation of interest while permitting source-State taxation subject to a reduced withholding limit for the beneficial owner, with exemptions for specified government and designated financial institutions. Interest is defined as income from debt claims (excluding late payment penalties). Interest is sourced to the payer's residence or to a State where a permanent establishment or fixed base bears the indebtedness. If the beneficial owner has a permanent establishment or fixed base and the interest is effectively connected, provisions of business profit or independent personal services Articles apply. Where a special relationship yields excess interest, treaty relief is confined to the arm's length amount.