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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.

ARTICLE 10

Dividends

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

(2) The term "dividends" herein shall mean income from shares, usufruct, mining, or shareholders shares or other rights which are not considered of debts and contribution to the profits, as well as the income of other contributions 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 company is situated.

(3) The provisions of paragraphs (1) and (2) 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 centre situated therein, and the ownership of the share, upon which the profits are paid, is effectively connected with such fixed centre. In such case, the provisions of Articles 7 or 14 of this Convention thereof, as the case may be, shall apply.