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of <h1>Interest Paid Across Borders: Tax Capped at 10% if Recipient is Beneficial Owner; Exemptions for Government, Financial Institutions.</h1> Interest arising in one Contracting State and paid to a resident of another may be taxed in the recipient's State. It can also be taxed in the State of origin, but if the recipient is the beneficial owner, the tax is capped at 10% of the gross interest. Exemptions apply if the interest is derived by certain governmental or financial institutions. 'Interest' includes income from debt-claims but excludes distributions under Article 10. The provisions don't apply if the interest is connected to a business or services in the other State. Special relationships affecting interest amounts are subject to specific tax rules.
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