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of <h1>Interest Taxed at Max 10% When Paid Across Borders; Exemptions for State Debtors; Adjustments for Special Relationships</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in the latter, but can also be taxed in the State where it arises, with a maximum tax rate of 10% if the beneficial owner is a resident of the other State. Exemptions apply if the debtor is the State or certain governmental entities. Interest is defined broadly, excluding penalty charges. Provisions do not apply if the interest is connected to a permanent establishment or fixed base. Special relationships affecting interest amounts are subject to adjustments, with excess taxed per local laws.
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