(1) Dividends paid by a company that is a resident of a Contracting State to a resident of another 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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed:
- (a) 10 per cent of the gross amount of the dividends, if the beneficiary owner is a company (with the exception of a partnership) which holds, directly, at least 25 per cent of the capital of the company paying the dividends;
- (b) 15 per cent of the gross amount of dividends, in all other cases.
The competent authorities of the Contracting States shall, by mutual agreement, settle the method of application of this limitation. This number does not affect the taxation of the company in respect of the profits out of which the dividends are paid.
(3) The term "dividends", as used in this Article, means income from shares, "jouissance" shares or "jouissance" bonuses, mining shares, founder's shares or other rights, not being debt claims, participating in profits, as well as income from other corporate rights which is subject to the same taxation treatment as income from shares by the laws of the State of which is the company making the distribution is a resident. The term "dividends" also includes profits attributed under an arrangement for participation in profits (“Association in participation