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of <h1>Cross-Border Interest Tax: 10% Cap with Exemptions for Government Entities and Intergovernmental Agreements. Special Rules for Business Activities.</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in the resident's State, but also in the State where it arises, with a tax cap of 10% if the recipient is the beneficial owner. Exemptions apply if the debtor is a government entity or if the interest is paid to a government or institution under an intergovernmental agreement. 'Interest' includes income from debt-claims, excluding penalty charges. Certain business activities in the State of interest origin may alter tax provisions. Special relationships affecting interest amounts are subject to specific tax regulations.
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