Cross-border interest tax limitation where recipient is beneficial owner; bank and government exemptions; PE-linked interest treated under business rules. Article 12 limits source-state taxation of interest paid to a resident beneficial owner, subject to reduced withholding for qualifying recipients and special relief for banks and government entities. Interest deemed to be connected with a permanent establishment or fixed base is taxed under business profits or independent personal services rules, and related-party excess payments are restricted to arm's length amounts.