Interest taxation: source state withholding capped where recipient is beneficial owner, with specific exemptions for public and export finance lenders.

Article 11 permits taxation of interest in the recipient's State and in the source State subject to a 15% cap when the recipient is the beneficial owner; exemptions remove source taxation where interest is beneficially owned by specified governments, central banks, or certain export finance or approved loans. Interest is defined as income from debt claims (excluding penalties); interest connected with a permanent establishment or fixed base is taxed under business profits or independent personal services provisions, and amounts above an arm's length interest are treated as excess taxable under domestic law.

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