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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, may be taxed in that other State.

(2) However, such dividends may also be taxed in the Contracting State in which the company paying the dividends is a resident and according to the laws of that State; but if the recipient is the beneficial owner of the dividends, the tax so charged shall not exceed sixteen percent of the gross amount of the dividends.

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

(3) The term "dividends" as used in this Article means income from shares, mining shares or founders' shares or other rights, not being debt-claims, 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 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, through a permanent establishment situated therein or performs in that other State independent personal services from a fixed base situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply.

(5) Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, then that other State may not impose any tax on the dividends paid by that company, except insofar as such dividends are paid to a resident of the other State, or insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment or fixed base situated in that other State. Further, the other State shall 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.