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of <h1>Interest Taxed in Both States with 15% Cap; Exemptions for Governments and Central Banks; Special Rules for Payer Location</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in both states, with a cap of 15% tax in the state of origin if the recipient is the beneficial owner. Exemptions apply for interest beneficially owned by governments, central banks, or approved residents. Interest is defined broadly, excluding penalty charges. The provisions do not apply if the interest is connected to a permanent establishment or fixed base. Interest is deemed to arise where the payer is located, and special relationships affecting interest amounts are subject to standard taxation rules.
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