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of <h1>Interest Taxed in Both Contracting States; Limited to 15% in State of Origin, Excludes Article 8 Interest.</h1> Interest arising in one Contracting State and beneficially owned by a resident of the other Contracting State may be taxed in the latter. It can also be taxed in the State where it arises, but the tax should not exceed 15% of the gross interest amount. 'Interest' includes income from government securities, bonds, debentures, and other indebtedness, excluding certain interest under Article 8. The provisions do not apply if the interest is connected to a business or services performed through a permanent establishment. Interest is deemed to arise where the payer is resident, unless linked to a permanent establishment elsewhere. Excessive interest due to special relationships is taxed according to each State's laws.
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