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of <h1>Article 11 of DTAA: Interest Taxed in Both States, 10% Cap if Beneficial Owner Resides Elsewhere. Exemptions Apply.</h1> Article 11 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of interest. Interest paid to a resident of the other Contracting State may be taxed in the recipient's State, but can also be taxed in the State where it arises, subject to a 10% cap if the beneficial owner resides in the other State. Exemptions apply if the interest is paid to governmental entities or institutions. The article defines 'interest' and outlines conditions where standard provisions do not apply, particularly concerning permanent establishments. Special relationships affecting interest amounts are also addressed.
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