Cross-border interest taxation: source-state tax limited where interest paid to nonresident beneficial owners, with specific exemptions. Article 11 permits residence taxation of interest and allows source state taxation subject to a limit when the recipient is the beneficial owner; it exempts specified public and government owned institutions. Interest is defined broadly as income from debt claims but excludes penalty charges. The Article disapplies source withholding where the beneficial owner has a permanent establishment or fixed base in the source State and the debt is effectively connected, directing application of business profit or independent services rules. Interest is deemed to arise where the payer is resident or where a permanent establishment bears the indebtedness. A special relationship rule restricts application to an arm's length amount, leaving excess to domestic taxation.