Interest taxation: source state may tax outbound interest with reduced withholding and exclusive taxation for specified government recipients. Article 11 allocates taxing rights over interest: interest paid to a resident may be taxed in the recipient's State and may also be taxed in the source State subject to a limited withholding where the beneficial owner is a resident. Interest paid to specified wholly government owned institutions is taxable only in the recipient's State. The Article defines interest comprehensively, excludes late payment penalties, carves out amounts effectively connected with a permanent establishment or fixed base to Articles 7/14, sets source rules based on payer residence or attributable permanent establishment, and applies an arm's length adjustment for special relationships.