Interest withholding tax cap for beneficial owners limits source-state taxation of cross-border interest under the DTAA. The DTAA permits both the residence State and the source State to tax cross-border interest, but limits source-State taxation when the recipient is the beneficial owner, with exemptions for certain public and central banking institutions. Interest is defined as income from debt-claims (excluding specified items); interest connected with a permanent establishment or fixed base is taxed under business or independent services rules. Special-relationship adjustments restrict treaty relief to arm's-length interest amounts, leaving any excess taxable under domestic law.