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of <h1>Interest Taxed in Recipient's State; Max 10% Tax if Beneficial Owner in State of Origin; Exemptions Apply</h1> Interest arising in one Contracting State and paid to a resident of the other State may be taxed in the recipient's State. However, it can also be taxed in the State where it arises, with a maximum tax rate of 10% if the recipient is the beneficial owner. Interest paid by a company resident in a Contracting State is not taxable if the beneficial owner is the government, central bank, or specified financial institutions of the other State. The term 'interest' excludes penalty charges for late payment. Exceptions apply if the interest is connected to a permanent establishment or fixed base. Special relationships affecting interest amounts are subject to specific provisions.
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