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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 which is a resident of a Contracting State to a resident of 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 company paying the dividends is a resident, and according to the laws of that State, but if the person receiving the dividends is the beneficial owner of those dividends, the tax thus charged shall not exceed 15 percent of the gross amount of the dividends.

This paragraph shall not affect the taxation of the company in respect to the profits out of which such dividends are paid.

The competent authorities of the Contracting States shall determine by mutual agreement the methods of application of such limitations.

(3) The term "dividend" as used in this Article refers to income from shares, 'jouissance' shares, mining shares, founders' shares or other rights, not being debt-claims, participating in profits, as well as the income from other corporate rights subject to the same taxation treatment as income from shares, according to the laws of the Contracting State of which the company making the distribution is a resident.

(4) The provisions of paragraphs (1) and (2) shall not apply if the beneficial owner 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, or carries on an industrial or commercial activity through a permanent establishment situated therein, or provides in that other State independent personal services from a fixed place of business situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed place of business. In this case, the dividends are taxable in the other Contracting State according to the domestic laws of that State.

(5) Where a company, which is a resident of a Contracting State, has a permanent establishment in the other Contracting State, any profits derived and not reinvested in the said Contracting State can be subject in the first-mentioned State to a tax imposed at the source. However, the tax so charged may not exceed 10 percent of the gross amount of any profits realized, after deduction of the tax applied to such profits.

(6) Subject to the provisions of paragraph (5) of this Article, where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not impose any tax on the dividends paid by the company except to the extent that such dividends are paid to a resident of that other State or to the extent that the holding in respect of which the dividends are paid is effectively connected with a permanent  establishment or a fixed place of business situated in that other State. Further, the other State may 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.