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of <h1>Interest Tax Capped at 10% for Beneficial Owners; Exempt for Certain Institutions; Special Rules for Business Connections</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in both states, but the tax in the source state is capped at 10% if the recipient is the beneficial owner. Interest is exempt from tax in the source state if derived by specified governmental or financial institutions. The term 'interest' includes income from debt-claims, excluding penalty charges. Exceptions apply if the interest is connected to a business or service in the source state. Interest is deemed to arise where the payer resides or where a permanent establishment incurring the debt is located. Special relationships affecting interest amounts are subject to specific provisions.
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