Interest withholding cap protects beneficial owners by limiting source-state tax on cross-border interest payments under tax treaty. Interest paid to a resident of the other Contracting State may be taxed in the recipient's State but may also be taxed at source; if the recipient is the beneficial owner, source tax is capped at ten per cent. Exemptions apply for interest beneficially owned by governments, specified central banks, and agreed institutions. Interest connected with a permanent establishment or fixed base is taxed under business or personal services provisions, interest is sourced to the payer's State unless attributable to such establishment, and related party excess interest is limited to the arm's length amount.