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of <h1>Interest Taxed in Both States, Capped at 15% for Beneficial Owners; Exempt for Government and Central Bank</h1> Interest arising in one Contracting State and paid to a resident of the other Contracting State may be taxed in both States, but the tax in the source State should not exceed 15% if the recipient is the beneficial owner. Interest is exempt from tax in the source State if derived by the government, central bank, or approved entities. The definition of interest includes income from debt-claims, excluding penalties for late payment. Provisions do not apply if the interest is connected to a permanent establishment in the source State. Excessive interest due to special relationships is taxable under each State's laws.
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