Taxation of interest: source taxation limited for beneficial owners while specific public and export financing exemptions apply. Interest may be taxed in the recipient's State of residence and also in the State where it arises; however, where the recipient is the beneficial owner, source taxation is subject to a withholding cap and specified exemptions apply for interest beneficially owned by governments, political sub-divisions, local authorities, the Central Bank, and certain export-import financing arrangements. Interest connected with a permanent establishment or fixed base is taxable under the rules for business profits or independent personal services, and amounts in excess of an arm's-length interest are taxable according to domestic law.