Interest taxation under the treaty: source withholding limited and exemptions for government and central bank ownership apply. The treaty permits taxation of interest by the recipient's residence State and also by the source State subject to a withholding tax ceiling when the beneficial owner is resident in the other Contracting State; exemptions apply for interest beneficially owned by the other State's government entities and central bank. Interest is broadly defined to include income from debt-claims and securities while excluding late payment penalties. Interest is deemed to arise where the payer is resident or where a permanent establishment bears the indebtedness; interest connected to a permanent establishment or fixed base of the beneficial owner is taxed under business or independent services provisions. Related-party excess interest is limited to arm's-length amounts for treaty relief, with the excess taxable under domestic law.