Interest taxation: cross-border withholding limited; governments and central banks exempt; permanent establishments change taxing rule.

Article 11 allocates interest taxation to the recipient's State while allowing source-state taxation subject to a reduced withholding when the beneficial owner is resident in the other State; exemptions apply for the other State, its subdivisions, specified central banks and agreed institutions. Interest connected with a permanent establishment or fixed base is taxed under business profits or independent personal services rules rather than under this Article. Interest is deemed to arise in the payer's State unless borne by a permanent establishment or fixed base elsewhere. Special-relationship excess interest is limited to an arm's-length amount, with the excess taxable domestically.

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