Interest taxation: residence state primary right, source state limited taxing power subject to beneficial owner and arm's length limits.
Article 11 grants the residence state primary taxing rights over cross-border Interest while permitting the source state a limited taxing right capped where the recipient is the beneficial owner resident of the other state; Article 11 also defines interest exhaustively for treaty purposes, displaces the article where interest is effectively connected to a permanent establishment (so that business profits rules apply), and conditions reduced source taxation on arm's-length pricing between related parties. (AI Summary)

Source-based taxation of artistes and sportspersons lets the performance country tax earnings while residence provides relief.
Article 17 grants the country where a performance occurs the right to tax income of entertainers and sportspersons based on the performance nexus; residence states retain taxing jurisdiction but must provide relief under treaty methods. The article covers direct performers and income paid to third parties as an anti avoidance rule, excludes non performing contributors absent a predominant entertainment element, and leaves tax base, deductions and collection rules to source state domestic law, creating potential for double taxation where source and residence rules diverge. (AI Summary)