Interest taxation: capped source-State tax on cross-border interest payments with specified exemptions and PE connection rule. Interest paid across the Contracting States may be taxed in the recipient's State while the source State may also tax such interest subject to a withholding limit when the beneficial owner is resident in the other State; specified public bodies and agreed institutions qualify for exemption. Interest is broadly defined as income from debt-claims, excludes items treated as dividends and late-payment penalties, and is treated as arising where the payer is resident or where a permanent establishment or fixed base bears the indebtedness. If interest is effectively connected to a PE or fixed base, business profits or independent services rules apply. Related-party excess interest is limited to an arm's-length amount.