Interest withholding limited on cross-border payments; source-state tax capped, exemptions for central banks and governments.

Cross-border interest payments are taxable in the recipient's residence State, while the source State may also tax such interest but at a reduced rate when the beneficial owner is resident in the other Contracting State; specified public entities and mutually agreed institutions are exempt. Interest is defined as income from debt claims, excluding dividends and penalty charges. A permanent establishment or fixed base connection places taxation under business or independent services rules, and special relationship adjustments limit treaty relief to arm's length interest amounts.

---

---

---