Taxation of cross-border interest: source state may tax but treaty caps withholding if beneficial owner is resident elsewhere. Interest on debt-claims may be taxed in the recipient's residence State; the source State may also tax such interest but is limited by a treaty cap where the beneficial owner is resident of the other Contracting State. Exemptions apply for payments to foreign governments, central banks, and wholly government-owned institutions. If the beneficial owner has a permanent establishment or fixed base in the source State and the debt is effectively connected, provisions for business profits or independent personal services govern. Related-party transactions are limited to an arm's-length amount.