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of <h1>Interest Taxation Rules Clarified: Bilateral Agreements Determine Rates for Cross-Border Financial Transactions Under Article 11</h1> The UN Model Tax Convention Article 11 governs interest taxation between contracting states. Interest can be taxed in the state of residence and source state, with a maximum tax rate to be negotiated bilaterally. The definition of interest includes debt-related income from various financial instruments. Exceptions apply if the interest is connected to a permanent establishment or fixed base. Special relationships between payer and recipient that result in excessive interest payments are subject to specific tax treatment under the provisions.
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