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of <h1>Article 11 of DTAA Limits Interest Tax to 10% for Beneficial Owners; Exemptions for Government Entities Apply</h1> Article 11 of the Double Tax Avoidance Agreement (DTAA) between two contracting states addresses the taxation of interest. Interest paid to a resident of one contracting state by another may be taxed in the recipient's state, but also in the state where it arises, with a maximum tax rate of 10% if the recipient is the beneficial owner. Exemptions apply for government entities and specified institutions. Interest is defined broadly, excluding penalties for late payment. Provisions do not apply if the interest is connected to a business or services conducted through a permanent establishment. Special relationships affecting interest amounts are subject to specific rules.
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