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of <h1>Interest Taxed in Both States, Capped at 10% for Beneficial Owners; Exemptions for Government Entities and 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, but can also be taxed in the source State, not exceeding 10% if the beneficial owner is a resident of the other State. Exemptions apply for government entities and specified financial institutions. Interest is defined broadly, excluding penalty charges. Provisions do not apply if the interest is connected to a permanent establishment or fixed base in the source State. Interest is deemed to arise in the payer's State unless linked to a permanent establishment elsewhere. Special relationships affecting interest amounts are addressed separately.
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