Interest taxation: source state may tax interest but capped when beneficial owner resides in the other Contracting State. Interest paid to a resident of the other Contracting State may be taxed in the recipient's State, but the source State may also tax it provided that where the beneficial owner is resident in the other State the source State's tax shall not exceed a 10 per cent withholding. Exemptions apply to interest derived by or in connection with loans from specified public and financial institutions listed for each State or as mutually agreed. Interest connected with a permanent establishment or fixed base is governed by the business or service articles, and related-party excess interest is limited to an arm's-length amount.