Interest Paid to Beneficial Owner Taxed at Max 10%; Exemptions for Government, Central Bank, and Permanent Establishments.

Interest arising in one Contracting State and paid to a resident of the other may be taxed in both states, but if the recipient is the beneficial owner, the tax in the state of origin shall not exceed 10%. The term "interest" includes income from debt-claims, government securities, and bonds. Exceptions apply if the interest is connected to a permanent establishment or fixed base. Interest is deemed to arise where the payer resides unless linked to a permanent establishment elsewhere. Special relationships affecting interest amounts are subject to standard taxation. Certain government and central bank interest is exempt from tax.

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