(1) Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State shall be taxed in that other State in accordance with its laws.
(2) Dividends mentioned in paragraph (1) shall also be taxed in the Contracting State of which the company paying the dividends is a resident according to the laws of that State. However, if the actual beneficial of the dividends is a resident of the other Contracting State then the tax so charged shall not exceed 10 % of the total amount of the dividends. The competent authorities of both Contracting States shall, where necessary, settle the question by mutual agreement.
(3) The term "dividends" as used in this Article means income from any shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the 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, is a resident of a Contracting State and 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, that other State may not impose any tax on the dividends paid by the company, except insofar as such dividends are paid to a resident of that other State or insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment or a fixed base situated in that other State.