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<h1>Cross-Border Interest Tax: Max 10% Rate in Source State, Exemptions for Government Entities and Financial Institutions</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's state, with a maximum tax rate of 10% in the source state if the beneficial owner resides in the other state. Exemptions apply for interest beneficially owned by government entities or specified financial institutions. Interest is defined as income from debt-claims, excluding penalty charges. Provisions do not apply if the interest is connected to a permanent establishment or fixed base in the source state. Interest is deemed to arise where the payer resides or where a connected permanent establishment is located. Special relationships affecting interest amounts are subject to standard taxation.