Interest withholding tax cap limits source-state taxation of cross-border interest, with exemptions for governments and central banks. The DTAA restricts source-state taxation of cross-border interest when the recipient is the beneficial owner by imposing a withholding tax cap; exemptions apply where interest is beneficially owned by a Contracting State's government, political sub-division or local authority, central bank, or approved wholly government-owned agency. Interest connected to a permanent establishment or fixed base is taxed under business profits or independent personal services provisions, interest is deemed to arise with the payer or the payer's permanent establishment bearing the indebtedness, and related-party excess interest is limited to an arm's-length amount.