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<h1>Interest Taxed at 10% Cap Between States with Exemptions for Government and Financial Institutions Under Certain Conditions</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 where it arises, capped at 10% if the beneficial owner is a resident of the other state. Exemptions apply if the interest is derived by government entities or designated financial institutions. 'Interest' includes income from debt-claims, excluding penalties for late payments. Provisions do not apply if the interest is connected to a permanent establishment or fixed base. Interest is deemed to arise where the payer resides unless linked to a permanent establishment. Excess interest due to special relationships remains taxable under local laws.