Interest taxation limits restrict source-state withholding on cross-border interest payments, subject to permanent establishment and related-party adjustments.

Article 11 allocates taxing rights over cross-border interest: residence States may tax interest paid to their residents, while source States may also tax such interest but are limited by specified withholding caps when the recipient is the beneficial owner. The Article defines interest as income from debt-claims, excludes penalty charges for late payment, and provides that permanent establishment or fixed base connections and special-relationship adjustments determine when business profits or arm's-length principles apply.

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