Interest withholding: limited source-state taxation allowed with exemptions and PE connections affecting taxation under treaty. Interest arising in a Contracting State may be taxed in the recipient's State of residence, while the source State may also tax such interest subject to constrained source state taxation when the beneficial owner is resident of the other State. Exemptions apply for interest beneficially owned by the Government, local authorities, designated government agencies, and, for legacy debt, certain banks. The Article excludes treaty relief where the recipient's permanent establishment or fixed base in the source State is effectively connected with the debt claim, and limits treaty benefit where interest exceeds arm's length amounts.