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of <h1>Article 11 of Canada DTAA Caps Tax on Cross-Border Interest at 15%, With Exemptions for Government Payments</h1> Article 11 of the Double Taxation Avoidance Agreement (DTAA) between Canada and another Contracting State addresses the taxation of interest income. Interest paid to a resident of one Contracting State by a payer in the other may be taxed in the recipient's state but can also be taxed in the payer's state, capped at 15% if the recipient is the beneficial owner. Exemptions exist for interest paid by government entities or central banks. Interest is defined broadly, excluding certain income types. Specific rules apply if the interest is connected to a permanent establishment or if special relationships affect the interest amount.
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