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of <h1>Article 11 of DTAA: Interest Taxation Rules, 10% Max Rate, Exemptions for Certain Entities, and Special Relationship Cases.</h1> Article 11 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of interest. Interest arising in one State and paid to a resident of the other may be taxed in the recipient's State but may also be taxed in the State where it arises, with a maximum tax rate of 10% if the recipient is the beneficial owner. Certain government entities and agreed agencies are exempt from tax. The article defines 'interest' and outlines exceptions where interest is connected to a permanent establishment or fixed base. It also addresses cases involving special relationships that affect the interest amount.
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