Interest withholding cap: treaty limits source-state tax on interest to beneficial owners and exempts governments and central banks. Article 11 permits source-state taxation of interest paid to residents of the other Contracting State but caps the source-state tax where the recipient is the beneficial owner; it exempts interest beneficially owned by the other State's government, political subdivisions, Central Bank, or agreed governmental agencies. 'Interest' is income from debt-claims, excluding penalties. If the beneficial owner's business is connected to the source State via a permanent establishment or fixed base and the debt is effectively connected, the provisions of the treaty for business profits or independent personal services apply. Special-relationship excess interest is limited to arm's length treatment under the Article.