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of <h1>Interest Taxation Rules: Cross-Border Payments, Beneficial Ownership, and Exemptions Under 10% Limit</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's state, but also in the state of origin, not exceeding 10% if the recipient is the beneficial owner. Exemptions apply for interest beneficially owned by government entities or specified banks. 'Interest' encompasses income from debt-claims, excluding penalty charges for late payment. Provisions do not apply if the interest is connected to a business or services conducted through a permanent establishment in the state of origin. Interest is deemed to arise where the payer resides, unless connected to a permanent establishment elsewhere. Special relationships affecting interest amounts are addressed separately.
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