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of <h1>Interest Taxed in Both States, Capped at 10% Unless Paid to Government Entities Under Certain Conditions</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in both states, with a maximum tax of 10% if the recipient is the beneficial owner. However, interest is taxable only in the recipient's state if it is derived by the government, central bank, or a wholly government-owned financial institution of that state. The term 'interest' includes income from debt-claims, government securities, bonds, and debentures. Exceptions apply if the interest is connected to a permanent establishment or fixed base in the source state. Special relationships affecting interest amounts are subject to specific limitations.
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