(1) Dividends paid by a company that is resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State.
(2) The term "dividends" as used in this Article means income from shares, "jouissance" shares or bonds, mining shares, founders' shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares under the laws of the State of which the company making the distribution is a resident.
(3) The provision of paragraph (1) and (2) of this Article shall not apply if the recipient of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein or performs in that other State independent personal services from a fixed base situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed base. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply.
(4) Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, then that other State may not impose any tax on the dividends paid by that company except insofar as such dividends are paid to a resident of that other State or where the holding in respect of which the dividends are paid is effectively connected with a permanent establishment or fixed base situated in that other State. Further, the other State shall not subject the company's undistributed profits to tax, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in that other State.