Taxation of interest: source withholding allowed with capped rates, exemptions for banks and public institutions. Taxation of interest under the Korea DTAA permits the recipient's State to tax interest but allows source-state taxation subject to withholding limits for the beneficial owner; banks and certain public institutions receive preferential or exempt source treatment. The Article broadly defines interest as income from debt-claims and provides that treaty withholding limits do not apply when interest is effectively connected to a permanent establishment or fixed base, in which case business profits or personal services rules apply. Interest is deemed to arise in the payer's State or, if borne by a permanent establishment or fixed base, in the State where that establishment or base is situated. Special-relationship adjustments limit treaty application to arm's-length amounts.