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CHAPTER 1 - General Provisions
CHAPTER 2 - Taxation of Income
CHAPTER 3 - Inheritance Tax
CHAPTER 4 - Registration Fees Other than Inheritance Tax-Stamp Duty
CHAPTER 5 - Administrative Assistance
CHAPTER 6 - Special Provisions
CHAPTER 7 - Transitional Provisions
CHAPTER 8 - Final Provisions
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 company which is a resident of a Member State to a resident of another Member State may be taxed in that other State.

(2) However, such dividends may also be taxed in the Member 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 their beneficial owner, the tax so charged shall not exceed 10% of the gross amount of the dividends.

(3) The term "dividends" as used in this Article means income from shares, “jouisance” shares or certificates, founders' shares or other beneficiary rights with the exception of debt-claims, as well as income similar to income from shares by the taxation law of the State of which the company making the distribution is a resident.

(4) The provisions of paragraphs (1) and (2) of this Article shall not apply if the beneficial owner of the dividends, being a resident of a Member State, carries on business in the other Member State of which the company paying the dividends is a resident, either an industrial or commercial activity through a permanent establishment situated therein, or independent personal services from a fixed base situated therein, and the holding in respect of which the dividends are paid is effectively connected therewith. In such case the provisions of Article 8 or Article 15 of this Regulation, as the case may be, shall apply.