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of <h1>Interest Taxed in Both States at 10% Max; Exemptions for Government, Local Authorities; Special Rules for Permanent Establishments</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in both States, with a maximum tax rate of 10% if the recipient is the beneficial owner. Exemptions apply if the payer or recipient is the government or a local authority. 'Interest' includes income from securities, bonds, and debt-claims. Provisions do not apply if the recipient has a permanent establishment in the other State connected to the debt-claim. Interest is deemed to arise where the payer is located or where a permanent establishment is situated. Special relationships affecting interest amounts are subject to specific provisions.
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