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of <h1>Interest Taxation Rules in DTAA: Article 11 Caps Tax at 10% for Beneficial Owners, Lists Exemptions and Special Conditions</h1> Article 11 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of interest. Interest paid from one Contracting State to a resident of the other may be taxed in the recipient's State, but also in the source State, with a maximum tax rate of 10% if the recipient is the beneficial owner. Exemptions apply for interest beneficially owned by government entities, central banks, or agreed financial institutions. The article defines 'interest' and specifies conditions under which the provisions do not apply, particularly when the interest is connected to a permanent establishment or fixed base. It also addresses situations involving special relationships affecting interest amounts.
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