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of <h1>Taxing cross-border interest: source withholding capped at 10% for beneficial owners, state-owned interest taxable only in owner's State</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in the recipient State, but may also be taxed at source, limited to 10% of gross interest where the beneficial owner is a resident of the other State; interest beneficially owned by a State or its subdivisions is taxable only in that owner's State. 'Interest' covers income from debt claims, including certain Islamic finance arrangements, but excludes penalty charges. Interest connected with a permanent establishment or fixed base is taxed under business/professional income rules. Where related-party pricing inflates interest, only arm's-length amounts qualify for treaty relief.
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