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of <h1>Interest Taxed at 15% Cap in Source State if Recipient is Beneficial Owner; Special Rules for Canada and India Residents</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in both States, but the tax in the source State is capped at 15% if the recipient is the beneficial owner. Exemptions apply if the payer is the government or a specified financial institution. Interest paid to residents of Canada or India under certain conditions is taxable only in the recipient's State. The definition of interest includes income from debt-claims but excludes income covered by other articles. Special provisions apply if the interest is connected with a permanent establishment or fixed base. Excess interest due to special relationships is taxable under each State's laws.
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