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of <h1>Interest Tax Capped at 10% for Beneficial Owners; Exemptions for Government, Central Bank, Financial Institutions</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State, and also in the State where it arises, but the latter's tax should not exceed 10% if the recipient is the beneficial owner. Exemptions apply for interest beneficially owned by the government, central bank, or approved financial institutions of the other State. Interest is defined broadly, excluding penalty charges. Specific provisions apply if the interest is connected to a permanent establishment or fixed base. Special relationships affecting interest amounts are subject to standard tax provisions.
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