Interest taxation: limited withholding on cross-border payments, exemptions for government entities and PE-connected income subject to beneficial owner rule. Interest arising in a Contracting State may be taxed in the recipient's State, but the source State may also tax such interest subject to a reduced withholding where the recipient is the beneficial owner. Interest is exempt in the source State when beneficially owned by the other State's government, political sub-division, local authority, or agreed agencies. Interest connected with a permanent establishment or fixed base is taxed under business or independent personal services provisions. Interest is sourced to the payer's State or to the State of the payer's PE or fixed base when incurred and borne by that establishment. Special-relationship excesses are limited to arm's-length amounts.