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of <h1>Interest Taxed in Both States, Capped at 10% for Bank Loans, 15% Otherwise; Exemptions for Government Entities</h1> Interest arising in one Contracting State and paid to a resident of the other may be taxed in both States, with limitations. If the beneficial owner resides in the other State, tax in the State of origin is capped at 10% for bank loans and 15% otherwise. Exemptions exist for interest derived by government entities or certain approved transactions. 'Interest' refers to income from debt-claims, excluding penalties and dividends. Provisions do not apply if the interest is connected to a business or services in the State of origin. Interest is deemed to arise where the payer is resident or has a permanent establishment. Special relationships affecting interest amounts may alter tax obligations.
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