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of <h1>Interest Taxed in Both States, Capped at 10% for Beneficial Owners; 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 both, but if the recipient is the beneficial owner, the tax in the source state shall not exceed 10%. Exemptions apply if the interest is owned by government entities or specific financial institutions. The term 'interest' includes income from debt-claims, excluding penalty charges. Provisions do not apply if the interest is connected to a permanent establishment or fixed base. Interest is deemed to arise where the payer is resident, unless linked to a permanent establishment. Excessive interest due to special relationships is subject to standard taxation.
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