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of <h1>Interest Taxed at 10% Maximum in Origin State; Exemptions for Government and Financial Institutions Apply</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's state, but also in the state where it arises, with a maximum tax rate of 10% if the recipient is the beneficial owner. Exemptions apply if the interest is derived by the government, central bank, or agreed financial institutions of the other state. The term 'interest' includes income from debt-claims, excluding penalty charges. Provisions do not apply if the interest is connected to business activities through a permanent establishment. Special relationships affecting interest amounts are subject to normal tax laws.
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