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of <h1>Article 11 of DTAA: Interest Taxed in Both States, 10% Cap for Beneficial Owners, Exemptions for Governments.</h1> Article 11 of the Double Tax Avoidance Agreement (DTAA) between two contracting states addresses the taxation of interest. Interest paid to a resident of one state by the other may be taxed in the resident's state, but also in the state where it arises, with a tax cap of 10% if the recipient is the beneficial owner. Certain entities, such as governments and central banks, are exempt from this tax. The article defines interest and outlines exceptions when the beneficial owner operates a business in the state where the interest arises. Special relationships affecting interest amounts are also addressed, limiting tax benefits to the standard interest amount.
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