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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.



(1) Dividends paid by a company resident in a Contracting State to a resident of the other Contracting State may be taxable only in the other Contracting State.

This paragraph shall not affect the taxation of a company in respect of profits on which dividends are paid.

(2) The term "dividends" herein shall mean income from shares, or other rights, which are not considered debts, or contribution to the profits, as well as the income of other contribution rights which are subject to similar taxes as they are deemed an income of the shares in accordance with the law of the State where the profit-distributing company is situated.

(3) The provisions of paragraph (1) hereof shall not apply if the beneficiary of profits is a resident of a Contracting State and carries out business in the other Contracting State, in which the company paying the profits through a permanent establishment resident therein, or performs in that other State independent professions through a fixed base situated therein, and the ownership of the share, upon which the profits are paid, is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Articles 8 or 15 thereof, as requires, shall apply.

(4) If a company resident in a Contracting State has achieved profits or an income from the other Contracting State, the other Contracting State may not impose any taxes on the dividends the company pays unless a same amount of such dividends are paid to a resident in the other Contacting State, or to the extent that the ownership property, upon which the dividends are paid, is actually connected with a permanent establishment or a fixed base in the other State. In addition, the State may not make the profits of the undistributed company subject to tax even if the dividends paid or the profits undistributed represent, wholly or partly, profits or income generated in the other State.