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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 legal entity who is a resident of a Contracting State to a person resident in the other Contracting State may be taxed in that other State.

(2) However, such dividends may also be taxed in the Contracting State of which the legal entity paying the dividends is a resident; but the tax so charged shall not exceed 15% of the gross amount of the dividends.

(3) The term "dividends" as used in this Article means income from shares, founders' shares or other rights (not being debt-claims) participating in profits, as well as income from other participations, which is subjected to the same treatment as income from shares by the laws of the State of which the legal person making the distribution is a resident.

(4) The provisions of paragraphs (1) and (2) shall not apply if the recipient of the dividends, being a resident of a Contracting State, carries on business activities in the other Contracting State from which the dividends are derived, through a permanent establishment situated therein, and the holding in respect of which the dividends are paid is effectively connected with this permanent establishment. In such case the provisions of Article 5 of this Convention shall apply.