Taxation of cross-border interest limited withholding where recipient is beneficial owner; exemptions and permanent establishment rules apply.

Interest paid to a resident of the other Contracting State may be taxed in the recipient State; however, if the recipient is the beneficial owner the source State may tax such interest subject to a withholding limitation. Exemptions from source taxation apply where interest is beneficially owned by public authorities or certain export finance or approved public financing institutions. The limitation does not apply where the beneficial owner has a permanent establishment or fixed base in the source State and the debt claim is effectively connected with it, and special relationship adjustments reduce taxable amounts to arm's length levels.

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