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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 that is a resident of a Contracting State to a resident of the other Contracting State and who is the beneficial owner of such dividends may be taxed solely in that other Contracting State.

(2) The term "dividends" as used in this Article means income from shares, "jouissance" shares or "jouissance" rights, mining shares, founders' shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights that is subject 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.