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of <h1>Interest Tax Capped at 10% for Beneficial Owners; Exemptions for Government, Financial Institutions</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in both States, but if the recipient is the beneficial owner, the tax in the source State is capped at 10%. Interest is exempt if derived by the government or certain financial institutions. 'Interest' includes income from debt claims, excluding penalty charges. The provisions do not apply if the interest is connected to a business or services in the source State. Interest is deemed to arise where the payer resides or operates a permanent establishment. Excess interest due to special relationships is taxable under domestic laws.
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