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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.



Dividends paid by a company that is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State according to the laws of that State. This provision shall not apply if a resident of a Contracting State owns permanent establishment in the other Contracting State and the profits are attributed to that permanent establishment. In such case, the provisions of Article 6 of this Convention shall apply.