Common use of Dividends Clause in Contracts

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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 or other rights, not being debt-claims, participating in profits and includes any income or distribution assimilated to income from shares under the taxation laws of the Contracting State of which the company paying the dividends or income or 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, 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds that owns directly at least 25 10 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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 or and other rights, not being debt-claims, participating in profits and includes any income or distribution assimilated to treated as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed baseestablishment. 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, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. 6. No relief shall be available under this Article if it was the main purpose or one of the main purposes of any person concerned with an assignment of the dividends, or with the creation or assignment of the shares or other rights in respect of which the dividend is paid, or the establishment, acquisition or maintenance of the company that is the beneficial owner of the dividends and the conduct of its operations, to take advantage of this Article. In any case where a Contracting State intends to apply this paragraph, the competent authority of that State shall consult with the competent authority of the other Contracting State.

Dividends. 1. Dividends paid by derived from a company which is a resident of a Contracting State to by 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 resident, and according to the laws of that State, but if recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 12.5 per cent of the gross amount of the dividends if the beneficial owner recipient is a company (other than a partnership) which holds controls directly or indirectly at least 25 10 per cent of the voting power of in the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This The provisions of this paragraph shall not affect the taxation of the company in respect of on the profits out of which the dividends are paid. 3. The term "dividends" as used in this Article means income from shares shares, or any other rights, not being debt-claims, participating in profits and includes any income or distribution assimilated to income item (other than interest relieved from shares tax under the taxation laws provisions of Article 11) which, under the law of the Contracting State of which the company paying the dividends or income or making the distribution dividend is a resident, is treated as a dividend or distribution of a company. 4. The provisions of paragraphs 1 and 2 of this Article shall not apply if where the beneficial owner of the dividends, being a resident of a one of the Contracting StateStates, carries on business has in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated thereinestablishment, or performs in that other State independent personal services from a fixed base situated therein, and the holding in respect by virtue of which the dividends are paid is effectively connected with the business carried on through such permanent establishment or fixed base. In such a 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 company and beneficially owned by persons who are paid to a resident not residents 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, nor or subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such that other State. 6. Nothing in this Agreement shall be construed as preventing a Contracting State from imposing on the earnings of a company attributable to a permanent establishment in that State, tax in addition to the tax which would be chargeable on the earnings of a company which is a national of that State, provided that any additional tax so imposed shall not exceed 12.5 per cent of the amount of such earnings which have not been subjected to such additional tax in previous taxation years. For the purpose of this provision, the term "earnings" means the profits attributable to a permanent establishment in a Contracting State in a year and previous years after deducting therefrom all taxes, other than the additional tax referred to herein, imposed on such profits by that State. 7. The provisions of this Article shall not apply if the right or property giving rise to the dividend was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged charge shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds owns directly or indirectly at least 25 10 per cent of the voting power share capital of the company paying the dividends; (b) in all other cases, 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paiddividends. 3. The term "dividends" as used in this Article means income from shares, "jouissance" shares or "jouissance" rights, mining shares, founders' shares or other rights, not being debt-debt- claims, participating in profits and includes any profits, as well as income or treated as a distribution assimilated to income from shares under by the taxation laws law of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 4. Where an investment vehicle organised under the laws of a Contracting State, (a) which derives income or gains from immovable property; (b) whose income or gains are not taxed; (c) which distributes most of its income annually, makes a distribution of income to a resident of the other Contracting State who is the beneficial owner of that distribution, the distribution of that income shall be treated as a dividend. However, where the beneficial owner holds, directly or indirectly, 10 per cent or more of the capital of the investment vehicle, the distribution may be taxed at the rate provided for by the domestic law of the Contracting State in which the distribution arises. 5. The provisions of paragraphs 1 1, 2 and 2 4 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 payer is a resident, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 56. 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, nor subject the company's undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. 7. Nothing in this Convention shall prevent a Contracting State from imposing on the profits attributable to a permanent establishment situated in that State, of a company which is a resident of the other Contracting State, a tax in addition to the taxes allowable under the other provisions of the Convention, provided that any additional tax so imposed shall not exceed 5 per cent of the profits attributable to the permanent establishment after the payment of corporate income tax on those profits.

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 resident, and according to the laws law of that State, but if the recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed:exceed - (a) 5 per cent 15 percent of the gross amount of the dividends if the beneficial owner recipient is a company (other than a including partnership) and during the part of the paying company's taxable year which holds directly precedes the date of payment of the dividend and during the whole of its prior taxable year (if any), at least 25 per cent 15 percent of the outstanding shares of the voting power stock of the paying company paying was owned by the dividends;recipient company; and (b) 15 per cent in all other cases 25 percent of the gross amount amounts of the dividends in all other casesdividends. This paragraph The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3. The provisions of paragraphs 1 and 2 shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 34. The term "dividends" as used in this Article means income from shares, "jouissance" shares or "jouissance" rights, mining shares, founders' shares or other rights, not being debt-debt- claims, participating in profits and includes any profits, as well as income or distribution assimilated to income from shares under by the taxation laws law of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 45. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner recipient 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, trade or business through a permanent establishment situated therein, or performs in that other State independent personal professional services from a fixed base situated therein, and the holding in respect by virtue of which the dividends are paid is effectively connected with such permanent establishment or fixed base. In such case a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 56. Where a company which is a resident of a Contracting State derives derived profits or income from the other Contracting State, that other State may not impose any tax on the dividends paid by the companycompany to persons who are resident of that State, 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 Contracting 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) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 50 per cent of the voting power of in the company paying the dividends;; and (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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, mining shares, founders' shares or other rights, not being debt-claims, rights participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, resident through a permanent establishment situated therein, therein or performs in that other Contracting 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 Contracting 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 Contracting 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 Contracting State, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State. 6. No relief shall be available under this Article if it is the main purpose or one of the main purposes of any person concerned with an assignment of the dividends, or with the creation or assignment of the shares or other rights in respect of which the dividend is paid, or the establishment, acquisition or maintenance of the company that is the beneficial owner of the dividends and the conduct of its operations, to take advantage of this Article. In any case where a Contracting State intends to apply this paragraph, the competent authority of that State shall consult with the competent authority of the other Contracting State.

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 Contracting 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) exceed 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. Notwithstanding the provisions of paragraph 2, dividends paid by a company which is a resident of a Contracting State to the Government of the other Contracting State or a local authority thereof or any agency or instrumentality (including a financial institution) wholly owned by that other Contracting State or local authority thereof shall be exempt from tax in the first-mentioned State. 4. The term "“dividends" ” as used in this Article means income from shares, “jouissance” shares or “jouissance” rights, mining shares, founders’ shares or other rights, rights not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subject to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 45. The provisions of paragraphs 1 1, 2 and 2 3 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. 56. 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, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

Dividends. 1. Dividends paid by a company which is a resident of a Contracting State Party to a resident of the other Contracting State Party, may be taxed in that other StateContracting Party. 2. However, such dividends may also be taxed in the Contracting State Party of which the company paying the dividends is a resident resident, and according to the laws of that StateContracting Party, but if the beneficial owner of the dividends is a resident of the other Contracting StateParty, the tax so charged shall not exceed: (a) 5 exceed 10 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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, founders’ shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State Party of which the company paying the dividends or income or 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 StateParty, carries on business in the other Contracting State Party of which the company paying the dividends is a resident, through a permanent establishment situated therein, or performs in that other State Contracting Party 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 Party derives income or profits or income from the other Contracting StateParty, that other State Contracting Party 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 Contracting Party 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 StateContracting Party, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of income or profits or income arising in such other StateContracting Party.

Dividends. 1. Dividends paid by derived from a company which is a resident of a Contracting State to by 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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent 12.5% of the gross amount of the dividends if the beneficial owner recipient is a company (other than a partnership) which holds controls directly or indirectly at least 25 per cent 10% of the voting power of in the company paying the dividends; (b) 15 per cent 15% of the gross amount of the dividends in all other cases. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. This paragraph shall 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 or other rights, not being debt-claims, participating in profits and includes any income or distribution assimilated to income from shares under the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 4. The provisions of paragraphs 1 and 2 of this Article shall not apply if where the beneficial owner of the dividends, being a resident of a Contracting State, carries on business has 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, therein and the holding in respect by virtue of which the dividends are paid is effectively connected with the business carried on through such permanent establishment or fixed base. In such case a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 54. 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 company to a resident of that other the first-mentioned State or except 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, State nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such that other State. 5. The provisions of this Article shall not apply if the right giving rise to the dividends was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. 6. The term "dividends" as used in this Article means income from 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 taxation law of the State of which the company making the distribution is a resident, and also any other item (other than interest relieved from tax under the provisions of Article 11 of this Agreement) which, under the law of the Contracting State of which the company paying the dividends is a resident, is treated as a dividend or distribution of a company. In the case of Belgium the term also means income which is taxable under the head of income on capital invested by the members of a company other than a company with share capital, which is a resident of Belgium.

Dividends. 1. Dividends paid by derived from a company which is a resident of a Contracting State to by 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 law of that State, but if where the beneficial owner recipient of the dividends a dividend is a resident of subject to tax thereon in the other Contracting State, State the tax so charged shall not exceed: (a) 5 per cent 12.5% of the gross amount of the dividends dividend, if the beneficial owner recipient is a company (other than a partnership) which holds controls directly or indirectly at least 25 per cent 10% of the voting power of in the company paying the dividendsdividend; (b) 15 per cent 15% of the gross amount of the dividends dividend in all other cases. This paragraph shall 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 or other rights, not being debt-claims, participating in profits and includes any income or distribution assimilated to income from shares under the taxation laws of the Contracting State of which the company paying the dividends or income or 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 Contracting State, carries on business has 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, therein and the holding in respect by virtue of which the dividends are paid is effectively connected with the business carried on through such permanent establishment or fixed base. In such case a case, the provisions provision of Article 7 or Article 14, as the case may be, shall apply. 54. 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 company and beneficially owned by persons who are paid to a resident not residents 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or on the undistributed profits consist wholly or partly of profits or income arising in such that other State. 5. The provisions of this Article shall not apply if the right giving rise to the dividends was created or assigned for reasons other than bona fide commercial consideration. 6. The term "dividends" as used in this Article means income from shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights assimilated to income from shares by the taxation law of the State of which the company making the distribution is a resident, and also any other item (other than interest relieved from tax under the provisions of Article 11) which, under the law of the Contracting State of which the company paying the dividend is a resident, is treated as a dividend or distribution of a company.

Dividends. 1. Dividends paid by a company which is a resident resident, or distributions made out of a real estate investment trust organised under the laws, of a Contracting State to a resident of the other Contracting State may be taxed in that other State. 2. However, such dividends or distributions may also be taxed in in, and according to the laws of, the Contracting State of which the company paying the dividends is a resident and according to or under whose laws the laws of that Statereal estate investment trust making the distributions has been organized, but if the beneficial owner of the dividends or distributions is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 in the case of dividends: (i) 0 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 10 per cent of the voting power capital of the company paying the dividends; (bii) 15 5 per cent of the gross amount of the dividends in all other cases; (b) in the case of distributions made out of the real estate investment trust: 5 per cent of the gross amount of the distributions if the beneficial owner of the distributions holds, directly or indirectly, less than 10 per cent of the value of the capital in such trust. This paragraph shall not affect the taxation of the company in respect profits of the profits company or the real estate investment trust out of which the dividends are paidpaid or the distributions are made. 3. The term "dividends" as used in this Article means income from shares, “jouissance” shares or “jouissance” rights, mining shares, founders’ shares or other rights, not being debt-debt- claims, participating in profits and includes any profits, as well as income or distribution assimilated which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 baseestablishment. 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 10 per cent of the voting power of in the company paying the dividends;; and (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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 or and other rights, not being debt-claims, participating in profits and includes any income or distribution assimilated to treated as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, resident through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed baseestablishment. 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, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 Contracting State. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in the that Contracting State of which the company paying the dividends is a resident and according to the laws of that Contracting 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) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 10 per cent of: (i) in the case where the company paying the dividends is a resident of Japan, the voting power of that company; (ii) in the case where the company paying the dividendsdividends is a resident of Morocco, the capital of that company; (b) 15 10 per cent of the gross amount of the dividends in all other cases. 3. This Notwithstanding the provisions of paragraph 2, dividends which are deductible in computing the taxable income of the company paying the dividends in the Contracting State of which that company is a resident may be taxed in that Contracting State according to the laws of that Contracting State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the dividends. 4. The provisions of paragraphs 2 and 3 shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 35. The term "“dividends" ” as used in this Article means income from shares, “jouissance” shares or “jouissance” rights, mining shares, founders’ shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as other income or distribution assimilated which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 46. The provisions of paragraphs 1 1, 2 and 2 3 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, resident through a permanent establishment situated therein, or performs in that other Contracting 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. 57. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other Contracting 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 Contracting 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: a) in the case of Austria: (ai) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power capital of the company paying the dividends; (ii) 15 per cent of the gross amount of the dividends in all other cases; b) in the case of Turkey: (i) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the capital of the company paying the dividends provided that such dividends are exempt from tax in Austria; (ii) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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" rights, founders' shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident, and income derived from an investment fund and investment trust . (4. ) Profits of a company of a Contracting State carrying on business in the other Contracting State through a permanent establishment situated therein may, after having been taxed under Article 7, be taxed on the remaining amount in the Contracting State in which the permanent establishment is situated, but the tax so charged shall not exceed 5 per cent of the remaining amount. (5) 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, 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 (6) Subject to the provisions of paragraph 4 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 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 Contracting State. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in the that Contracting State of which the company paying the dividends is a resident and according to the laws of that Contracting 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) 5 exceed 10 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent dividends. The provisions of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This this paragraph shall 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 or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, resident through a permanent establishment situated therein, or performs in that other Contracting 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 Contracting 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 Contracting 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

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. However, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) exceed 15 per cent of the gross amount of the dividends in all other casesdividends. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. The provisions of this paragraph shall not limit application of the Additional Tax payable in Chile provided that the First Category Tax is creditable in computing the amount of additional tax. 3. The term "dividends" as used in this Article means income from shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 Contracting State. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in the that Contracting State of which the company paying the dividends is a resident and according to the laws of that Contracting 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) 5 exceed 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of paragraph 2, dividends paid by a company which is a resident of a Contracting State shall be taxable only in the other Contracting State if the beneficial owner of the dividends is a resident of that other Contracting State and is either: (a) a company (other than a partnership) which holds has owned directly or indirectly, for the period of six months ending on the date on which entitlement to the dividends is determined, at least 25 10 per cent of the voting power of the company paying the dividends;; or (b) 15 per cent a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of the gross amount subparagraph (l) of the dividends in all other casesparagraph 1 of Article 3. 4. This paragraph The provisions of paragraphs 2 and 3 shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 35. The provisions of subparagraph (a) of paragraph 3 shall not apply in the case of dividends paid by a company which is entitled to a deduction for dividends paid to its beneficiaries in computing its taxable income in the Contracting State of which the company paying the dividends is a resident. 6. The term "dividends" as used in this Article means income from shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 47. The provisions of paragraphs 1 1, 2 and 2 3 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, resident through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 58. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other Contracting 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 Contracting 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 Contracting State, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 20 per cent of the voting power capital of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of these limitations. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. Notwithstanding the provisions of paragraphs 1 and 2, dividends paid by a company which is a resident of a Contracting State shall be taxable only in the other Contracting State if the beneficial owner of the dividends is the Government of that other State, or the Central Bank thereof, or any other government institution thereof or statutory body as may be agreed from time to time between the competent authorities of the Contracting States. 4. The term "dividends" as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 45. 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. 56. 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 10 per cent of the gross amount of the dividends if the beneficial owner recipient is a company (other than a excluding partnership) which holds directly at least 25 per cent of the voting power capital of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. Notwithstanding the provisions of paragraphs 1 and 2, dividends paid by a company which is a resident of a Contracting State to the Government of the other Contracting State shall be exempt from tax in the first-mentioned State. 4. For the purposes of paragraph 3 the term "Government" shall have the same meaning as in paragraph 4 of Article 11. 5. The term "dividends" as used in this Article means income from shares, "jouissance" shares or "jouissance" rights, founders' shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 46. Profits of a company of a Contracting State carrying on business in the other Contracting State through a permanent establishment situated therein may, after having been taxed under Article 7, be taxed on the remaining amount in the Contracting State in which the permanent establishment is situated and in accordance with sub-paragraph (a) of paragraph 2 of this Article. 7. 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 in the case of a resident of Turkey, performs in that other State Singapore independent personal services from a fixed base situated thereinin Singapore, 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. 58. Where Subject to the paragraph 6 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 insofar as such dividends are paid to a resident of that other Contracting 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such that other State.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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 or other rights, not being debt-debt- claims, participating in profits and includes any income or distribution assimilated to income from shares under the taxation laws of the Contracting State of which the company paying the dividends or income or 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, 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 resident, and according to the laws of that State, but if the recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds has owned directly or indirectly at least 25 per cent of the voting power capital of the company paying the dividendsdividends for a period of at least 12 months preceding the date the dividends were declared; (b) 15 10 per cent of the gross amount of the dividends in all other cases. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of these limitations. This paragraph shall 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" rights, mining shares, founders' shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, therein or performs in that other State independent personal services from a fixed base situated therein, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed base. In such a case the provisions of Article 7 or Article 14, as the case may be, shall applydividends are taxable in that other Contracting State according to its own law. (Art. 10 contd.) 5. Where a company which is a resident of a Contracting State 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, nor subject the company's undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 Contracting 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 Contracting 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) 5 exceed 15 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of paragraph 2, dividends shall not be taxed in the Contracting State of which the company paying the dividends is a resident if the beneficial owner of the dividends is a resident of the other Contracting State and is a company (other than a partnership) that has owned directly or indirectly, for the period of six months ending on the date on which holds directly entitlement to the dividends is determined, at least 25 10 per cent of the voting power of the company paying the dividends and the company that is the beneficial owner of the dividends: (a) is a qualified person by reason of the provisions of subparagraph (c) of paragraph 2 of Article 22; (b) 15 has at least 50 per cent of its voting power in the gross amount aggregate owned directly or indirectly by five or fewer companies referred to in subparagraph (a); or (c) is granted benefits with respect to those dividends under paragraph 5 of the dividends in all other casesArticle 22. 4. This paragraph The provisions of paragraphs 2 and 3 shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 35. The provisions of paragraph 3 shall not apply in the case of dividends paid by a company which is entitled to a deduction for dividends paid to its beneficiaries in computing its taxable income in the Contracting State of which the company is a resident. 6. The term "“dividends" ” as used in this Article means income from shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated which is subjected to the same taxation treatment as income from shares under by the taxation tax laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 47. The provisions of paragraphs 1 1, 2 and 2 3 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, resident through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 58. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other Contracting 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 Contracting 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

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 Contracting State. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in the that Contracting State of which the company paying the dividends is a resident and according to the laws of that Contracting 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) 5 exceed 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of paragraph 2, dividends paid by a company which is a resident of a Contracting State shall be taxable only in the other Contracting State if the beneficial owner of the dividends is a resident of that other Contracting State and is a company (other than a partnership) which holds has owned, directly or indirectly, at least 25 10 per cent of the voting power of the company paying the dividends; (b) 15 per cent dividends for the period of six months ending on the gross amount of date on which entitlement to the dividends in all other casesis determined. 4. This paragraph The provisions of paragraphs 2 and 3 shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 35. The provisions of paragraph 3 shall not apply in the case of dividends which are deductible in computing the taxable income of the company paying the dividends in the Contracting State of which that company is a resident. 6. The term "“dividends" ” as used in this Article means income from shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 47. The provisions of paragraphs 1 1, 2 and 2 3 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, resident through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 58. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other Contracting 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 Contracting 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power capital of the company paying the dividends; (b) 15 10 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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" rights, mining shares, founders’ shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 baseestablishment. In such case 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, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 10 per cent of the voting power capital of the company paying the dividends; (b) 15 10 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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 or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 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 1415, 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 exceed 10 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. The term "dividends" dividends " as used in this Article means income from shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, 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 1415, 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) exceed 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. Notwithstanding the provisions of paragraph 2, dividends arising in a Contracting State and paid to, and beneficially owned by, the Government of the other Contracting State shall be exempt from tax in the first-mentioned State. 4. The term "“dividends" ” as used in this Article means income from shares, “jouissance” shares or “jouissance” rights, mining shares, founders’ shares or other rights, rights (not being debt-claims, ) participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 45. 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, resident through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 56. 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, nor subject the company's ’s undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 Contracting State. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in the that Contracting State of which the company paying the dividends is a resident and according to the laws of that Contracting 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) 5 exceed 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of paragraph 2, dividends if the beneficial owner paid by a company which is a company (resident of a Contracting State and beneficially owned by a person, other than an individual, who is a partnership) which holds directly at least 25 per cent resident of the voting power other Contracting State shall be taxable only in that other Contracting State. 4. The provisions of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph paragraphs 2 and 3 shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 35. The provisions of paragraph 3 shall not apply in the case of dividends which are deductible in computing the taxable income of the company paying the dividends in the Contracting State of which the company is a resident. 6. The term "“dividends" ” as used in this Article means income from shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 47. The provisions of paragraphs 1 1, 2 and 2 3 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, resident through a permanent establishment situated therein, or performs in that other Contracting 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. 58. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other Contracting 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 Contracting 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

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 Contracting 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 Contracting State, but if the recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power capital of the company paying the dividends; (b) 15 10 per cent of the gross amount of the dividends in all other cases. This The provisions of this paragraph shall 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 shares, or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 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 Contracting 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 1414 of this Agreement, 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 Contracting 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 Contracting 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

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 recipient is the beneficial owner of the dividends is a resident of the other Contracting Statedividends, the tax so charged shall not exceed: (a) 5 per cent exceed 15 percent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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 or other rights, not being debt-debt claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 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 income or 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of income or profits or income arising in such other State. Nothing in this paragraph shall be construed as preventing a Contracting State from imposing income tax, according to the laws of that State, on the disposal of profits made by a permanent establishment situated therein.

Dividends. 1. Dividends paid by a company which is a resident of a Contracting State one of the States 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 recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent 12.5% of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent 10% of the voting power capital of the company paying the dividends; (b) 15 per cent 15% of the gross amount of the dividends in all other cases. This paragraph shall 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 shares, or other rights, not being debt-claims, claims participating in profits and includes any as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 Contracting Stateone of the States, 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 one of the States 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 paid by a company which is a resident of a Contracting State: a) 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: (ai) 5 10 per cent of the gross amount of the dividends if the beneficial owner is a company dividends, except as provided in sub-paragraph a) (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividendsii); (bii) 15 per cent of the gross amount of the dividends where those dividends are paid by a relevant investment vehicle; b) shall, notwithstanding the provisions of sub-paragraph a), be exempt from tax in all the Contracting State of which the company paying the dividends is a resident if the beneficial owner of the dividends is: (i) a company (other casesthan a partnership) which is a resident of the other Contracting State and controls, directly or indirectly, at least 10 per cent of the voting power in the company paying the dividends (other than where the dividends are paid by a relevant investment vehicle); or (ii) a pension scheme. This paragraph shall 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” rights, mining shares, founders’ shares or other rights, not being debt-claims, participating in profits and includes profits, as well as any income or distribution assimilated other item which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, resident through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed baseestablishment. 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, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such that other State. (6) For the purposes of paragraph 2, a relevant investment vehicle means: a) in Austria, a real estate investment fund which meets the conditions of the Austrian Act on Real Estate Investment Funds (“Immobilien- Investmentfondsgesetz”); and b) in the United Kingdom, a real estate investment trust within the meaning of Part 12 of Corporation Tax Xxx 0000 and a property authorised investment fund within the meaning of Part 4A of the Authorised Investment Funds (Tax) Regulations 2006 (SI 2006/964). The competent authorities of the Contracting States may agree to regard as a relevant investment vehicle similar arrangements or entities established in a Contracting State.

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 Contracting State. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in the that Contracting State of which the company paying the dividends is a resident and according to the laws of that Contracting 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) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds has owned directly or indirectly, for the period of six months ending on the date on which entitlement to the dividends is determined, at least 25 10 per cent of: (i) in the case where the company paying the dividends is a resident of Iceland, the capital of that company; or (ii) in the case where the company paying the dividends is a resident of Japan, the voting power of the company paying the dividends;that company; or (b) 15 per cent of the gross amount of the dividends in all other cases. 3. This Notwithstanding the provisions of paragraph 2, dividends paid by a company which is a resident of a Contracting State shall be taxable only in the other Contracting State if the beneficial owner of the dividends is a resident of that other Contracting State and is either: (a) a company which has owned directly or indirectly, for the period of six months ending on the date on which entitlement to the dividends is determined, at least 25 per cent of: (i) in the case where the company paying the dividends is a resident of Iceland, the capital of that company; or (ii) in the case where the company paying the dividends is a resident of Japan, the voting power of that company; or (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of paragraph 1 of Article 3. 4. The provisions of paragraphs 2 and 3 shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 35. The provisions of subparagraph (a) of paragraph 2 and paragraph 3 shall not apply in the case of dividends which are deductible in computing the taxable income of the company paying the dividends in the Contracting State of which that company is a resident. 6. The term "“dividends" ” as used in this Article means income from shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 47. The provisions of paragraphs 1 1, 2 and 2 3 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, resident through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 58. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other Contracting 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 Contracting 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

Dividends. (1. ) Dividends paid by a company which is a resident of a one of the Contracting State States for the purposes of its tax, being dividends to which a resident of the other Contracting State is beneficially entitled, may be taxed in that other State. (2. However, such ) Such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident for the purposes of its tax, and according to the laws law 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) 5 exceed 20 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends;. (b3) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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 or and other rights, not being debt-claims, participating in profits and includes any income or distribution assimilated to income from shares under by the taxation laws law, relating to tax, of the Contracting State of which the company paying the dividends or income or making the distribution is a residentresident for the purposes of its tax. (4. ) The provisions of paragraphs 1 (l) and 2 (2) shall not apply if the beneficial owner of person beneficially entitled to the dividends, being a resident of a one of the Contracting StateStates, carries on business in the other Contracting State of which the company paying the dividends is a resident, 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 a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. (5. Where ) Dividends paid by a company which is a resident of one of the Contracting States, being dividends to which a Contracting State derives profits or income from person who is not a resident of the other Contracting Statecontracting State is beneficially entitled, shall be exempt from tax in 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 of fixed base situated in that other State. Provided that this paragraph shall not apply in relation to dividends paid by any company which is a resident of Australia for the purposes of Australian tax and which is also a resident of Fiji for the purposes of Fiji tax. (6) Nothing in this Agreement shall be construed as preventing one of the Contracting States from imposing, nor subject the company's undistributed profits to a tax on the company's undistributed profitsincome of a company which is a resident of the other Contracting State, even if tax in addition to the dividends paid or taxes referred to in Article 2 in relation to the firstmentioned State, provided that any such additional tax shall not exceed 20 per cent of the amount by which the taxable income of the firstmentioned company of a year of income exceeds the tax payable on that taxable income to the firstmentioned State. Any tax payable to one of the Contracting State on the undistributed profits consist wholly or partly of profits or income arising a company which is a resident of the other Contracting State shall be calculated as if that company were not liable to the additional tax referred to in this paragraph and had paid dividends of such other Stateamount that tax equal to the amount of the additional tax would have been payable on the dividends in accordance with paragraph (2).

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 resident, and according to the laws law of that State, but if the recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent 10% of the gross amount of the dividends if the beneficial owner recipient is a company (other than a partnership) which holds owns directly at least 25 per cent 25% of the voting power capital of the company paying the dividends; (b) 15 per cent 15% of the gross amount of the dividends in all other cases. This The provisions of this paragraph shall not affect the taxation of the company in respect of on 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” rights, mining shares, founders’ shares or other rights, not being debt-debt- claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, 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, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. 6. Notwithstanding any other provisions of this Agreement, where a company which is a resident of a Contracting State has a permanent establishment in the other Contracting State, the profits of the permanent establishment may be subjected to an additional tax in that other State in accordance with its law, but the additional tax so charged shall not exceed 10 per cent of the amount of such profits after deducting therefrom income tax and other taxes on income imposed thereon in that other State. 7. The provisions of paragraph 6 of this Article shall not affect the provision contained in any production sharing contracts relating to oil and gas, and contract of works for other mining sectors, concluded by a Contracting State or its relevant state oil and gas company or any other entity thereof with a person who is a resident of the other Contracting State.

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 recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) exceed 15 per cent of the gross amount of the dividends in all other casesdividends. This paragraph shall 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" rights, mining shares, founders' shares or other rights, rights not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, 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 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 Contracting 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

Dividends. 1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may shall 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 recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) exceed 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. Notwithstanding the provisions of paragraph 2 of this Article, as long as Malaysia does not impose a tax on dividends in addition to the tax chargeable on the profits or income of a company, dividends paid by a company which is a resident of Malaysia to a resident of Bahrain shall be exempt from any tax in Malaysia which may be chargeable on dividends in addition to the tax chargeable on the profits or income of the company. However, where Malaysia imposes a tax on dividends in addition to the tax chargeable on the profits or income of a Company, the rate as prescribed under the provisions of paragraph 2 shall apply. 4. The term "dividends" as used in this Article means income from shares, "jouissance" shares or "jouissance" rights, mining shares, founders' shares or other rights, rights not being debt-claims, participating in profits and includes any profits, as well as income or treated as distribution assimilated to income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 45. 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 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 baseestablishment. In such case a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 56. Where a company which is a resident of a Contracting State derives income or 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 company to persons who are paid to a resident not residents 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, nor or subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of income or profits or income arising in such other State.

Dividends. 1. Dividends paid by a company which is a resident of a Contracting State Party to a resident of the other Contracting State Party may be taxed in that other StateParty. 2. However, such dividends may also be taxed in the Contracting State Party of which the company paying the dividends is a resident and according to the laws of that StateParty, but if the beneficial owner of the dividends is a resident of the other Contracting StateParty, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 10 per cent of the voting power capital of the company paying the dividends; (b) 15 10 per cent of the gross amount of the dividends in all other cases. The competent authorities of the Contracting Parties shall by mutual agreement settle the mode of application of these limitations. This paragraph shall 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” rights, mining shares, founders’ shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State Party of which the company paying the dividends or income or 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 StateParty, carries on business in the other Contracting State Party of which the company paying the dividends is a resident, through a permanent establishment situated therein, or performs in that other State Party 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 Party derives profits or income from the other Contracting StateParty, that other State Party 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 Party 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 StateParty, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other StateParty.

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 Contracting State. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in the that Contracting State of which the company paying the dividends is a resident and according to the laws of that Contracting 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) 5 per cent of the gross amount of the dividends if the beneficial owner is a company which has owned directly or indirectly, throughout a 365 day period that includes the date on which entitlement to the dividends is determined (other than for the purpose of computing that period, no account shall be taken of changes of ownership that would directly result from a partnership) which holds directly corporate reorganisation, such as a merger or divisive reorganisation, of the company that is the beneficial owner of the dividends or that pays the dividends), at least 25 20 per cent of: (i) in the case where the company paying the dividends is a resident of Jamaica, the capital or voting power of that company; or (ii) in the case where the company paying the dividends is a resident of Japan, the voting power of the company paying the dividends;that company; or (b) 15 10 per cent of the gross amount of the dividends in all other cases. 3. This Notwithstanding the provisions of paragraph 2, dividends which are deductible in computing the taxable income of the company paying the dividends in the Contracting State of which that company is a resident may be taxed in that Contracting State according to the laws of that Contracting State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the dividends. 4. The provisions of paragraphs 2 and 3 shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 35. The term "“dividends" ” as used in this Article means income from shares, “jouissance” shares or “jouissance” rights, mining shares, founders’ shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 46. The provisions of paragraphs 1 1, 2 and 2 3 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, resident through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 57. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other Contracting 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 Contracting 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

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 resident, and according to the laws law of that State, but if the beneficial owner of the dividends is a resident of the other Contracting StateState is the beneficial owner of the dividends, the tax so charged shall not exceed: (a) 5 per cent exceed 15% of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent dividends. The provisions of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. The limitation of tax to 15% of the gross amount of dividends mentioned in paragraph 2 refers to the tax imposed on dividends in addition to the tax imposed on the profits of a company. 4. The term "dividends" as used in this Article means income from shares, mining shares, founders' shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated to income from shares under by the taxation laws law of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 45. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner recipient 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 therein with which the holding in respect by virtue of which the dividends are paid is effectively connected with such permanent establishment or fixed baseconnected. In such case a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 56. 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. 7. Dividends shall be deemed to arise in a Contracting State if the dividends are paid by a company which is resident in that Contracting State.

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 Contracting State. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in the that Contracting State of which the company paying the dividends is a resident and according to the laws of that Contracting 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) 5 exceed 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of paragraph 2, dividends paid by a company which is a resident of a Contracting State shall be taxable only in the other Contracting State if the beneficial owner of the dividends is a resident of that other Contracting State and is either: (a) a company (other than a partnership) which holds has owned directly or indirectly, for the period of six months ending on the date on which entitlement to the dividends is determined, at least 25 10 per cent of the voting power of the company paying the dividends;; or (b) 15 per cent a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of the gross amount subparagraph (l) of the dividends in all other casesparagraph 1 of Article 3. 4. This paragraph The provisions of paragraphs 2 and 3 shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 35. The provisions of subparagraph (a) of paragraph 3 shall not apply in the case of dividends paid by a company which is entitled to a deduction for dividends paid to its beneficiaries in computing its taxable income in the Contracting State of which the company paying the dividends is a resident. 6. The term "“dividends" ” as used in this Article means income from shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 47. The provisions of paragraphs 1 1, 2 and 2 3 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, resident through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 58. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other Contracting 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 Contracting 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

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 recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent 5% of the gross amount of the dividends if the beneficial owner is a company (other has contributed, directly or indirectly, more than a partnership) which holds directly at least 25 per cent 50% of the voting power capital of the company paying the dividends or more than US$10 million; (b) 7% of the gross amount of the dividends if the beneficial owner has contributed, directly or indirectly, between 25% and 50% of the capital of the company paying the dividends; (bc) 15 per cent 12.5% of the gross amount of the dividends in all other cases. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. Notwithstanding the provisions of paragraphs 1 and 2, dividends paid by a company which is a resident of Vietnam to the Government of Singapore shall be exempt from Vietnamese tax. 4. For the purposes of paragraph 3, the term "Government of Singapore" shall have the same meaning as in paragraph 4(a) of Article 11. 5. The term "dividends" as used in this Article means income from shares, mining shares, founders' shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 46. 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, 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 case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 57. 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 Contracting 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such that other State. 8. Notwithstanding the provisions of paragraph 2 of this Article, as long as Singapore does not impose a tax on dividends in addition to the tax chargeable on the profits or income of a company, dividends paid by a company which is a resident of Singapore to a resident of Vietnam shall be exempt from any tax in Singapore which may be chargeable on dividends in addition to the tax chargeable on the profits or income of the company.

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 Contracting 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 recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) exceed 5 per cent percent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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” rights, mining shares, founders’ shares or other rights, not being debt-claimsdebt‑claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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: (a) shall be exempt from tax in the Contracting State of which the company paying the dividends is a resident if the beneficial owner is a company which is a resident of the other Contracting State and controls, directly or indirectly, at least 50 per cent of the voting power in the company paying the dividends and has invested at least £2 million (or the equivalent amount in the currency of Georgia) in the share capital of the company paying the dividends at the date of payment of the dividends; (b) except as provided in sub-paragraph (a) of this paragraph, 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: (ai) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds controls, directly or indirectly, at least 25 10 per cent of the voting power of in the company paying the dividends; (bii) 15 10 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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, mining shares, founders’ shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident and also includes any other item which, under the laws of the State of which the company paying the dividend is a resident, is treated as a dividend or distribution of a company. (4. ) The provisions of paragraphs 1 (1) and 2 (2) of this Article 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 baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, of this Agreement 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, nor subject the company's ’s undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such that other State. (6) The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the shares or other rights in respect of which the dividend is paid to take advantage of this Article by means of that creation or assignment.

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 Dividends paid by a company 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) 5 per cent Malaysia to a resident of the gross amount of the dividends if Egypt who is the beneficial owner thereof shall be exempt from any tax in Malaysia which is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the chargeable on dividends in all other cases. This paragraph shall not affect addition to the taxation of the company tax chargeable in respect of the profits out income of the company. Nothing in this paragraph shall affect the provisions of the Malaysian law under which the dividends are tax in respect of a dividend paid by a company which is a resident of Malaysia from which Malaysian tax has been, or has been deemed to be, deducted may be adjusted by reference to the rate of tax appropriate to the Malaysian year of assessment immediately following that in which the dividend was paid. 3. The term "dividends" as used in this Article means income from shares, "jouissance" shares or "jouissance" rights, mining shares, founders shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 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 baseestablishment. In such case a 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 in so far as such dividends are paid to a resident of that other State or insofar in so far 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, profits even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent percent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly has owned at least 25 per cent percent of the voting power stock of the company paying the dividends;dividends for a 12 month period ending on the date the dividend is declared; and (b) 15 per cent percent of the gross amount of the dividends in all other cases. This paragraph shall 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" rights, mining shares, founder's shares, or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 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 case, the provisions of Article 7 or Article 14, as the case may be, shall applydividends are taxable in that other Contracting State according to its own laws. 5. Where a company which is a resident of a Contracting State and not a resident of the other 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, except as provided in paragraph 6, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. 6. A corporation that is a resident of one of the States and that has a permanent establishment in the other State or that is subject to tax in the other State on a net basis on its income that may be taxed in the other State under Article 6 (Income from Immovable Property) or under paragraph 1 of Article 13 (Capital Gains) may be subject in that other State to a tax in addition to the tax allowable under the other provisions of this Convention. Such tax, however, may be imposed on only the portion of the business profits of the corporation attributable to the permanent establishment and the portion of the income referred to in the preceding sentence that is subject to tax under Article 6 (Income from Immovable Property) or under paragraph 1 of Article 13 (Capital Gains) that, in the case of the United States, represents the dividend equivalent amount of such profits or income and, in the case of Italy, is an amount that is analogous to the dividend equivalent amount. 7. The tax referred to in paragraph 6 may not be imposed at a rate in excess of the rate specified in paragraph 2(a). 8. Notwithstanding paragraph 2, dividends shall not be taxed in the Contracting State of which the company paying the dividends is a resident if the beneficial owner of the dividends is a resident of the other Contracting State that is a qualified governmental entity that holds, directly or indirectly, less than 25 percent of the voting stock of the company paying the dividends.

Dividends. 1. Dividends paid or credited by a company which is a resident of a Contracting State to wholly or mainly out of profits, income or gains derived from sources in the JPDA, and which are beneficially owned by a resident of the other Contracting State State, may be taxed in that other Contracting State. 2. However, such dividends may also be taxed in the first-mentioned Contracting State of which the company paying the dividends is a resident and according to the laws law 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: exceed fifteen (a15) 5 per cent of the gross amount of the dividends if the beneficial owner dividends. 2. Dividends paid or credited by a company which is a company (other than resident of a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall not affect the taxation of the company in respect of the profits Contracting State wholly or mainly out of profits, income or gains derived from sources in the JPDA, and which the dividends are paidbeneficially owned by a resident of that Contracting State, shall be taxable only in that State. 3. Dividends paid or credited by a company which is a resident of a Contracting State wholly or mainly out of profits, income or gains derived from sources in the JPDA, and which are beneficially owned by a person who is not a resident of either Contracting State, may be taxed in both Contracting States but the taxable amount of any such dividends shall be an amount equivalent to the framework percentage of the amount that would be the taxable amount but for this paragraph. 4. The term "dividends" as used in this Article means income from shares or other rights, not being debt-claims, rights participating in profits and includes any not relating to debt claims, as well as other income or distribution assimilated which is subjected to the same taxation treatment as income from shares under by the taxation laws law of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 45. The Notwithstanding any other provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividendsthis Taxation Code, 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 where a company which is a resident of a Contracting State derives profits profits, income or gains from the JPDA, such profits, income from or gains may be subject in the other Contracting State, that other State may not impose any to a tax on profits after income tax in accordance with its law, but such tax shall not exceed fifteen (15) per cent of the dividends paid by gross amount of such profits, income or gains after deducting from those profits, income or gains 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 income tax imposed on them in that other State. Such tax shall be imposed upon the amount equivalent to the framework percentage of the amount that would be taxed but for this paragraph. 6. For the purposes of this Article, nor subject "derived from" has the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising same meaning as expressed in such other StateArticle 5.

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 Contracting 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 Contracting State, but if the recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 7 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power shares of the company paying the dividends; (b) 15 10 per cent of the gross amount of the dividends dividents in all other cases. This the provisions of this paragraph shall 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 or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 Contracting 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 of 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 Contracting 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 Contracting 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such that other Contracting State.

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 Contracting 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) exceed 5 per cent of the gross amount of the dividends. Notwithstanding the provision of sentence above, the Contracting State of which the company paying the dividends if is a resident shall exempt from tax the beneficial owner is dividends paid by that company to a company (other than a partnership) which is a resident of the other Contracting State, as long as it holds directly at least 25 per cent of the voting power capital of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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” rights, mining shares, founders' shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 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 article 7 or Article article 14, as the case may be, 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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, 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 recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent exceed 15 percent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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 or other rights, rights not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, 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 Contracting 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, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 exceed 10 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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 shares, or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, 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, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

Dividends. 1. Dividends arising in a territory and paid by a company which is a resident of a Contracting State to a resident of the other Contracting State territory may be taxed in that other Stateterritory. 2. However, such dividends may also be taxed in the Contracting State of territory in which the company paying the dividends is a resident they arise, and according to the laws law of that Stateterritory, but if the beneficial owner of the dividends recipient who is a resident of the other Contracting Stateterritory beneficially owns the dividends, the tax so charged shall not exceed: (a) 5 per cent of exceed an amount which together with the gross amount of corporate income tax payable on the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power profits of the company paying the dividends; (b) 15 per cent dividends constitutes 40% of that part of the gross amount of the dividends in all other cases. This paragraph shall not affect the taxation of the company in respect of the profits taxable income out of which the dividends are paiddeclared. The term "corporate income tax payable" shall be deemed to include the corporate income tax which would have been paid but for the reduction or exemption under the laws designed to promote economic development. 3. Where no dividend tax is imposed in addition to the corporate income tax on the profits of the company, the provisions of paragraph 2 shall not apply. 4. The term "dividends" as used in this Article means income from shares, mining shares, founders' shares or other rights, right not being debt-debt claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subject to the same taxation treatment as income from shares under according to the taxation laws of law in the Contracting State territory of which the company paying the dividends or income or making the distribution is a resident. 45. The provisions of paragraphs 1 and paragraph 2 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting Stateterritory, carries on business has in the other Contracting State territory, 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 with which the holding in respect by virtue of which the dividends are paid is effectively connected with such permanent establishment or fixed baseconnected. In such case a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 56. Where a company which is a resident of a Contracting State territory derives profits or income from the other Contracting Stateterritory, no tax may be imposed in that other State may not impose any tax territory on the dividends paid by the company, company except insofar as such dividends are paid to a resident of that other State territory 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 Stateterritory, nor subject or on the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Stateterritory. 7. Dividends shall be deemed to arise in a territory if they are paid by a company resident in that territory.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power capital of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of these limitations. The provisions of this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. The provisions of this paragraph shall not limit application of the Additional Tax payable in Chile provided that the First Category Tax is fully creditable in computing the amount of additional tax. 3. The term "“dividends" ” as used in this Article means income from shares or other rights, rights participating in profits (not being debt-claims), participating in profits and includes any as well as income or distribution assimilated from other rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, resident through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case 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 in so far as such dividends are paid to a resident of that other State or insofar in so far 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, nor subject the company's ’s undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. 6. The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the shares or other rights in respect of which the dividend is paid to take advantage of this Article by means of that creation or assignment.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company dividends, except as provided in subparagraph (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividendsb); (b) 15 per cent of the gross amount amounts of the dividends in all other caseswhere those dividends are paid out of income (including gains) derived directly or indirectly from immovable property within the meaning of Article 6 by an investment vehicle which distributes most of this income annually and whose income from such immovable property is exempted from tax. The competent authorities of the Contracting States shall settle the mode of application of these limitations by mutual agreement. This paragraph shall 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 shares, or other rights, not being debt-claims, participating in profits and includes profits, as well as any income or distribution assimilated other item which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, resident through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case 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, nor subject the company's ’s undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such that other State. 6. No relief shall be available under this Article if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the shares or other rights in respect of which the dividend is paid to take advantage of this Article by means of that creation or assignment.

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 Contracting State. 2. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident resident, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 10 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly owns at least 25 10 per cent of the voting power stock of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This The provisions of this paragraph shall 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 or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 Contracting 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 Contracting 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 Contracting 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such that other Contracting State. 6. Notwithstanding any provision in this Agreement, a company which is a resident of the People’s Republic of China and which has permanent establishments in Canada, shall, in accordance with the provisions of Canadian law, remain subject to the additional tax on companies other than Canadian corporations, but the rate of such additional tax shall not exceed 10 per cent. For the purpose of this paragraph, the term “earnings” means the profits attributable to such permanent establishments in Canada in a year and previous years after deducting therefrom: (a) business losses attributable to such permanent establishments (including losses from the alienation of property forming part of the business property of such permanent establishments) in such year and previous years, (b) all taxes chargeable in Canada on such profits, other than the additional tax referred to herein, and (c) the profits reinvested in Canada, provided that the amount of such deduction shall be determined in accordance with the existing provisions of the law of Canada regarding the computation of the allowance in respect of investment in property in Canada, and any subsequent modification of those provisions which shall not affect the general principle hereof. 7. The additional tax referred to in paragraph 6 shall be levied only to the extent that the cumulative amount of earnings of the company, or of a person related thereto from the same or similar business as that carried on by the company, exceeds five hundred thousand Canadian dollars ( $ 500, 000) .

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 resident, and according to the laws of that State, but if the recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 5% per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds has owned directly or indirectly at least 25 25% per cent of the voting power capital of the company paying the dividendsdividends for a period of at least 12 months preceding the date the dividends were declared; (b) 15 15% per cent of the gross amount of the dividends in all other cases. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of these limitations. This paragraph shall 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” rights, mining shares, founders’ shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, therein or performs in that other State independent personal services from a fixed base situated therein, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed base. In such a case the provisions of Article 7 or Article 14, as the case may be, shall applydividends are taxable in that other Contracting State according to its own law. 5. Where a company which is a resident of a Contracting State State, derives profits or income from the other Contracting State, 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 resident, and according to the laws of that State, but if the recipient is the beneficial owner of the dividends is a resident of the other Contracting Statedividends, the tax so charged shall not exceed: (a) 5 per cent Ten (10) percent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly owns at least 25 per cent ten (10) percent of the voting power shares of the company paying the dividends; (b) 15 per cent Twelve and one half (12 1/2) percent of the gross amount of the dividends in all other cases. This paragraph shall 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 or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, 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 case, the provisions of Article 7 or Article 1415, as the case may be, shall apply. 5. Where a company which is a resident of a Contracting State 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, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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, 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 recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 exceed 10 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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 shares, or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 State, of which the company paying the dividends is a resident, 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 case, the provisions of Article 7 or Article 1415, 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 Contracting 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, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

Dividends. 1. Dividends paid by a company which is a resident of a Contracting State Party to a resident of the other Contracting State Party may be taxed in that other StateParty. 2. However, such dividends may also be taxed in the Contracting State Party of which the company paying the dividends is a resident and according to the laws of that StateParty, but if the beneficial owner of the dividends is a resident of the other Contracting StateParty, the tax so charged shall not exceed: (a) 5 exceed 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of paragraph 2, the Contracting Party of which the company paying the dividends is a resident shall not levy a tax on dividends paid by that company, if the beneficial owner is of the dividends is: (a) a company (other than a partnership) which is resident of the other Contracting Party and which holds directly at least 25 10 per cent of the voting power capital of the company paying the dividends;; or (b) 15 per cent a pension fund or pension scheme; or (c) in the case of the gross amount Hong Kong Special Administrative Region, the Hong Kong Monetary Authority; and in the case of Switzerland, the Swiss National Bank. 4. The competent authorities of the dividends Contracting Parties shall by mutual agreement settle the mode of application of the limitations mentioned in all other casesparagraphs 2 and 3. This paragraph Paragraphs 2 and 3 shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 35. The term "“dividends" ” as used in this Article means income from shares, “jouissance” shares or “jouissance” rights, mining shares, founders’ shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State Party of which the company paying the dividends or income or making the distribution is a resident. 46. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting StateParty, carries on business in the other Contracting State Party of which the company paying the dividends is a resident, through a permanent establishment situated therein, or performs in that other State Party 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. 57. Where a company which is a resident of a Contracting State Party derives profits or income from the other Contracting StateParty, that other State Party 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 Party 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 StateParty, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other StateParty. 8. The provisions of this Article shall not apply in respect of any dividends paid in the course of a transaction or series of transactions which is structured in such a way that a resident of a Contracting Party entitled to the benefits of this Agreement receives an item of income arising in the other Contracting Party but the resident pays, directly or indirectly, all or substantially all of that income (at any time or in any form) to another person who is not a resident of either Contracting Party and who, if it received that item of income directly from the other Contracting Party, would not be entitled under an agreement for the avoidance of double taxation between the Party in which that other person is resident and the Contracting Party in which the income arises, or otherwise, to benefits with respect to that item of income which are equivalent to, or more favourable than, those available under this Agreement to a resident of a Contracting Party and the main purpose of such structuring is obtaining benefits under this Agreement.

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 Contracting 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 Contracting State, but if the recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 10 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 10 per cent of the voting power capital of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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 shares, mining shares, founder's shares, or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 Contracting 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 a permanent establishment or fixed base. In such case a 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 Contracting 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 Contracting 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 Contracting State, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

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 Contracting 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 Contracting State, but if the recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 exceed seven per cent (7 per cent) of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent dividends. The provisions of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. Notwithstanding the provisions of paragraphs 1 and 2, dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State shall be taxable only in that other Contracting State if the beneficial owner of the dividend is: (a) the Government of that other Contracting State or any of its institutions; or other entity the capital of which is wholly-owned directly or indirectly by the Government of that other Contracting State; or (b) a company which is a resident of that other Contracting State whose shares are at least 20% owned directly or indirectly by the Government of that other Contracting State. 4. The term "dividends" as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 45. 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 Contracting 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. 56. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other Contracting 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 Contracting 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 Contracting State, . nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

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 beneficial owner of the dividends is are beneficially owned by a resident of the other Contracting State, the tax so charged shall not exceed:, except as otherwise provided, (a) 5 per cent cent. of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds that owns shares representing directly or indirectly at least 25 10 per cent cent. of the voting power of the company paying the dividends; (b) 15 per cent cent. of the gross amount of the dividends in all other cases. This paragraph shall 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 Notwithstanding the provisions of paragraph 2 of this Article, dividends shall not be taxed in this Article means income from shares or other rights, not being debt-claims, participating in profits and includes any income or distribution assimilated to income from shares under the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a residentresident if the beneficial owner of the dividends is a resident of the other Contracting State and either: (a) a company that has owned shares representing 80 per cent. or more of the voting power of the company paying the dividends for a 12-month period ending on the date the dividend is declared, and that: (i) owned shares representing, directly or indirectly, at least 80 per cent. of the voting power of the company paying the dividends prior to October 1st, 1998; or (ii) is a qualified person by reason of sub-paragraph (c) of paragraph 2 of Article 23 (Limitation on Benefits) of this Convention; or (iii) is entitled to benefits with respect to the dividends under paragraph 3 or paragraph 6 of that Article; or (b) a pension scheme, provided that such dividends are not derived from the carrying on of a business, directly or indirectly, by such pension scheme. 4. Sub-paragraph (a) of paragraph 2 and paragraph 3 of this Article shall not apply in the case of dividends paid by a pooled investment vehicle which is a resident of a Contracting State. Sub- paragraph (b) of paragraph 2 of this Article shall apply in the case of dividends paid by a pooled investment vehicle, the assets of which consist wholly or mainly of shares, securities or currencies or derivative contracts relating to shares, securities or currencies. In the case of dividends paid by a pooled investment vehicle not described in the preceding sentence, sub-paragraph (b) of paragraph 2 of this Article shall apply only if: (a) the beneficial owner of the dividends is an individual holding an interest of not more than 10 per cent. in the pooled investment vehicle; (b) the dividends are paid with respect to a class of stock that is publicly traded and the beneficial owner of the dividends is a person holding an interest of not more than 5 per cent. of any class of the stock of the pooled investment vehicle; or (c) the beneficial owner of the dividends is a person holding an interest of not more than 10 per cent. in the pooled investment vehicle and that vehicle is diversified. 5. The previous provisions of paragraphs 1 and 2 this Article 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 State, of which the company paying the dividends payer 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 attributable to such permanent establishment or fixed baseestablishment. In such case case, the provisions of Article 7 or Article 14, as the case may be, (Business Profits) of this Convention shall apply. 56. Where A Contracting State may not impose any tax on dividends paid by 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 the dividends are paid to a resident of that other the first-mentioned State or insofar as the holding in respect of which the dividends are paid is effectively connected with attributable to a permanent establishment or a fixed base situated in that other State, nor subject the company's undistributed profits to a may it impose tax on the a company's ’s undistributed profits, except as provided in paragraph 7 of this Article, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other that State. 7. A company that is a resident of a Contracting State and that has a permanent establishment in the other Contracting State, or that is subject to tax in that other State on a net basis on its income (a) prior to October 1st, 1998 was engaged in activities giving rise to profits attributable to that permanent establishment or to income or gains to which the provisions of Article 6 or, as the case may be, paragraph 1 of Article 13 apply; (b) is a qualified person by reason of sub-paragraph (c) of paragraph 2 of Article 23 (Limitation on Benefits) of this Convention; or (c) is entitled to benefits under paragraph 3 or paragraph 6 of that Article with respect to an item of income, profit or gain described in this paragraph. 8. The additional tax referred to in paragraph 7 of this Article may not be imposed at a rate in excess of the rate specified in sub-paragraph (a) of paragraph 2 of this Article. 9. The provisions of this Article shall not apply in respect of any dividend paid under, or as part of, a conduit arrangement. 10. For the purposes of this Article:

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) exceed 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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, mining shares, founders’ shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 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, nor subject the company's undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 resident, and according to the laws of that State, but if the recipient is the beneficial owner of the dividends is a resident of the other Contracting Statedividends, the tax so charged shall not exceed: (a) 5 with respect to dividends paid by a company which is a resident of Thailand to a resident of Israel - 10 per cent of the gross amount of the dividends; (b) with respect to dividends paid by a company which is a resident of Israel to a resident of Thailand: (i) 10 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which recipient holds directly at least 25 per cent of the voting power capital of the company paying the dividends; (bii) 15 per cent of the gross amount of the dividends in all other cases. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of these limitations. This paragraph shall 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, mining shares, founders' shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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, 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. Nothing in this paragraph shall be construed as preventing a Contracting State from imposing income tax, according to the laws of that State, on the disposal of profits made by a permanent establishment situated therein at a rate not exceeding the rate applicable to dividends in terms of paragraph 2 (a) of this Article.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 20 per cent of the voting power of in the company paying the dividends;, and (b) 15 per cent of the gross amount of the dividends dividends, in all other cases. This paragraph shall 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 or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 baseestablishment. 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. 6. The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the shares or other rights in respect of which the dividend is paid to take advantage of this Article by means of that creation or assignment.

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 recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power share capital of the company paying the dividends; (b) 15 10 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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 or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated to from other corporate rights which is subjected in the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 baseestablishment. 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 income or 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 company to persons who are paid to a resident not residents 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, nor or subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of income or profits or income arising in such other State.

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 resident, and according to the laws of that State, but if the recipient is the beneficial owner of the th dividends and is a resident company, other than a partnership, which holds directly at least 25 per cent of the other Contracting Statecapital of the former company, the tax so charged shall not exceed: (a) 5 per cent 15 percent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividendsdividends engages in an industrial undertaking; (b) 15 per cent 20 percent of the gross amount of the dividends in all other cases. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of these limitations. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. (a) The term "“dividends" ” as used in this Article means income from shares shares, mining shares,founders’shares or other rights, not being debt-claims, participating in profits and includes any income or distribution assimilated profits, as well asincome from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. (b) The term “industrial undertaking” as used in this Articlemeans (i) any undertaking engaged in - manufacturing, assembling and processing; - construction, civil engineering and shipbuilding; - production of electricity, hydraulic power, gas or the supply of water ; or - agriculture, forestry and fishery and the carrying on of a plantation, and (ii) any other undertaking entitled to the privileges accorded under the laws of Thailand on the promotion of industrial investment, and (iii) any other undertaking which may be declared to be an “industrial undertaking” for the purpose of this Article by the competent authority of Thailand. 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, 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, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: exceed ten (a10) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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, mining shares, founders’ shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 income or 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, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of income or profits or income arising in such other State. Nothing in this paragraph shall be construed as preventing a Contracting State from imposing income tax, according to the laws of that State, on the disposal of profits made by a permanent establishment situated therein.

Dividends. 1. Dividends paid or credited by a company which is a resident of a Contracting State to wholly or mainly out of profits, income or gains derived from sources in the JPDA, and which are beneficially owned by a resident of the other Contracting State State, may be taxed in that other Contracting State. 2. However, such dividends may also be taxed in the first-mentioned Contracting State of which the company paying the dividends is a resident and according to the laws law 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: exceed fifteen (a15) 5 per cent of the gross amount of the dividends if the beneficial owner dividends. 2. Dividends paid or credited by a company which is a company (other than resident of a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall not affect the taxation of the company in respect of the profits Contracting State wholly or mainly out of profits, income or gains derived from sources in the JPDA, and which the dividends are paidbeneficially owned by a resident of that Contracting State, shall be taxable only in that State. 3. Dividends paid or credited by a company which is a resident of a Contracting State wholly or mainly out of profits, income or gains derived from sources in the JPDA, and which are beneficially owned by a person who is not a resident of either Contracting State, may be taxed in both Contracting States but the taxable amount of any such dividends shall be an amount equivalent to the framework percentage of the amount that would be the taxable amount but for this paragraph. 4. The term "dividends" as used in this Article article means income from shares or other rights, not being debt-claims, rights participating in profits and includes any not relating to debt claims, as well as other income or distribution assimilated which is subjected to the same taxation treatment as income from shares under by the taxation laws law of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 45. The Notwithstanding any other provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividendsthis Taxation Code, 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 where a company which is a resident of a Contracting State derives profits profits, income or gains from the JPDA, such profits, income from or gains may be subject in the other Contracting State, that other State may not impose any to a tax on profits after income tax in accordance with its law, but such tax shall not exceed fifteen (15) per cent of the dividends paid by gross amount of such profits, income or gains after deducting from those profits, income or gains 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 income tax imposed on them in that other State. Such tax shall be imposed upon the amount equivalent to the framework percentage of the amount that would be taxed but for this paragraph. 6. For the purposes of this article, nor subject "derived from" has the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising same meaning as expressed in such other Statearticle 5.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed:; (a) 5 per cent except as provided in sub-paragraph 2 (b) such dividends shall be exempt from tax in the Contracting State of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividendsdividends is a resident; (b) other than where the beneficial owner of the dividends is a pension scheme, where dividends are paid out of income derived directly or indirectly from immovable property within the meaning of Article 6 by an investment vehicle which distributes most of this income annually and whose income from such immovable property is exempted from tax, the tax charged by the Contracting State of which the company paying the dividends is a resident shall not exceed 15 per cent of the gross amount of the dividends in all other casesdividends. This paragraph shall 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 shares, or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident and also includes any other item which, under the laws of the State of which the company paying the dividend is a resident, is treated as a dividend or distribution of a company. (4. ) The provisions of paragraphs 1 (1) and 2 (2) of this Article 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 baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, of this Agreement 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such that other State. (6) The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the shares or other rights in respect of which the dividend is paid to obtain a tax advantage under this Article by means of that creation or assignment.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) exceed 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. Notwithstanding the provisions of paragraph 2, dividends arising in a Contracting State and paid to, and beneficially owned by, the Government of the other Contracting State shall be exempt from tax in the first-mentioned State. 4. The term "“dividends" ” as used in this Article means income from shares, “jouissance” shares or “jouissance” rights, mining shares, founders’ shares or other rights, rights (not being debt-debt- claims, ) participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 45. 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, resident through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 56. 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, nor subject the company's ’s undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 Contracting 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 Contracting State, but if the recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power capital of the company paying the dividends; (b) 15 10 per cent of the gross amount of the dividends in all other cases. This The provisions of this paragraph shall 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 shares, or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 Contracting 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 Contracting 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 Contracting 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

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 Contracting 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 Contracting 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) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) that has owned directly, for the period of six months ending on the date on which holds directly entitlement to the dividends is determined, at least 25 per cent of the voting power of in the company paying the dividends;; or (b) 15 per cent of the gross amount of the dividends in all other cases. This The provisions of this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. Notwithstanding the provisions of paragraph 2, such dividends shall not be taxed in the Contracting State of which the company paying the dividends is a resident if the beneficial owner of the dividends is a pension fund which is a resident of the other Contracting State, provided that such dividends are not derived from the carrying on of a business by such pension fund or through an associated enterprise. 4. The provisions of paragraphs 2 and 3 shall not limit the application of the Additional Tax payable in Chile. 5. The term "“dividends" ” as used in this Article means income from shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other rights which is subjected to the same taxation treatment as income from shares under by the taxation tax laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 46. The provisions of paragraphs 1 and 2 to 4 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, resident through a permanent establishment situated therein, or performs in that other Contracting 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. 57. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other Contracting 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 Contracting 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

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 recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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 or other rights, not being debt-debt- claims, participating in profits and includes any income or distribution assimilated to income from shares under the taxation laws of the Contracting State of which the company paying the dividends or income or 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, 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 Contracting 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 Contracting State, but if the beneficial owner of but: (a) where the dividends are paid by a company which is a resident of China to a resident of Malta who is the other Contracting Statebeneficial owner thereof, the Chinese tax so charged shall not exceed: (a) 5 exceed 10 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent where the dividends are paid by a company which is a resident of Malta to a resident of China who is the beneficial owner thereof, the Malta tax on the gross amount of the dividends in all other casesshall not exceed that chargeable on the profits out of which the dividends are paid. This paragraph shall 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 shares, or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 Contracting 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 Contracting 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 Contracting 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent % of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 10 per cent of the voting power capital of the company paying the dividends; (b) 15 per cent 10 % of the gross amount of the dividends in all other cases. This paragraph shall 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 or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. (4. ) The provisions of paragraphs 1 (1) and 2 (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, 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 0 per cent of the gross amounts of the dividends if the beneficial owner is a company which holds directly or indirectly at least 50 per cent of the capital of the company paying the dividends and has invested more than 2 million Euro in the capital of the company paying the dividends; (b) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly or indirectly at least 25 10 per cent of the voting power capital of the company paying the dividends and has invested more than 100,000 Euro in the capital of the company paying the dividends; (bc) 15 10 per cent of the gross amount of the dividends in all other cases. The competent authorities of the Contracting State shall by mutual agreement settle the mode of application of these limitations. This paragraph shall 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 shares, or other rights, not being debt-debt claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, 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, 14 of this Agreement 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: exceed 10 (aten) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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, mining shares, founders' shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 income or 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 such permanent establishment or a fixed base situated in that other State, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of income or profits or income arising in such other State. Nothing in this paragraph shall be construed as preventing a Contracting State from imposing income tax, according to the laws of that State, on the disposal of profits made by a permanent establishment situated therein.

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 Contracting 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 Contracting State, but if the recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) exceed 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent dividends. The provisions of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This this paragraph shall 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 shares, mining shares, founders’ shares, or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 Contracting 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 Contracting State may not impose any tax on the dividends paid by the company, except insofar in so far as such dividends are paid to a resident of that other Contracting State or insofar in so far 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

Dividends. 1. (a) Dividends paid by derived from a company which is a resident of a Contracting State to the United Kingdom by a resident of the other Contracting State Cyprus may be taxed in that other StateCyprus. (b) Where a resident of Cyprus is entitled to a tax credit in respect of such a dividend under paragraph (2. However, such dividends ) of this article tax may also be taxed charged in the Contracting State of which the company paying the dividends is a resident United Kingdom and according to the laws of the United Kingdom, on the aggregate of the amount or value of that Statedividend and the amount of that tax credit at a rate not exceeding 15 per cent. (c) Except as aforesaid dividends derived from a company which is a resident of the United Kingdom and which are beneficially owned by a resident of Cyprus shall be exempt from any tax in the United Kingdom which is chargeable on dividends. (2) A resident of Cyprus who receives dividends from a company which is a resident of the United Kingdom shall, but if subject to the provisions of paragraph (3) of this article and provided he is the beneficial owner of the dividends is a resident of the other Contracting Statedividends, be entitled to the tax so charged credit in respect thereof to which an individual resident in the United Kingdom would have been entitled had he received those dividends, and to the payment of any excess of that tax credit over his liability to United Kingdom tax. (3) Paragraph (2) of this article shall not exceed: (a) 5 per cent of the gross amount of the dividends if apply where the beneficial owner of the dividend is a company (other than a partnership) which holds either alone or together with one or more associated companies controls directly or indirectly at least 25 10 per cent of the voting power of in the company paying the dividends;dividend. For the purposes of this paragraph two companies shall be deemed to be associated if one is controlled directly or indirectly by the other, or both are controlled directly or indirectly by a third company. (b4) 15 per cent Dividends derived from a company which is a resident of Cyprus and which are beneficially owned by a resident of the gross amount of the United Kingdom shall be exempt from any tax in Cyprus which is chargeable on dividends in all other cases. This paragraph shall not affect addition to the taxation of the company tax chargeable in respect of the profits out or income of which the dividends are paidcompany. 3. (5) The term "dividends" as used in this Article article means income from shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution from other corporate rights assimilated to income from shares by the taxation law of the Contracting State of which the company making the distribution is a resident and also includes any other item (other than interest relieved from tax under the taxation laws provisions of article 12 of this Convention) which under the law of the Contracting State of which the company paying the dividends or income or making the distribution dividend is a resident, is treated as a dividend or distribution of a company. 4. The provisions of paragraphs 1 and 2 shall not apply if (6) If the beneficial owner of the dividends, being a resident of a one of the Contracting StateStates, carries on business owns 10 per cent or more of the class of shares in respect of which the other Contracting State dividends are paid then paragraphs (1) and (2) or, as the case may be, paragraph (4) of this article shall not apply to the dividends to the extent that they can have been paid only out of profits which the company paying the dividends earned or other income which is received in a residentperiod ending 12 months or more before the relevant date. For the purposes of this paragraph the term "relevant date" means the date on which the beneficial owner of the dividends became the owner of 10 per cent or more of the class of shares in question. Provided that this paragraph shall apply only if the shares were acquired primarily for the purpose of securing the benefit of this article and not for bona fide commercial reasons. (7) The provisions of paragraphs (1) and (2) or, through as the case may be, paragraph (4) of this article shall not apply where a resident of one of the Contracting States has in the other Contracting State 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 by virtue of which the dividends are paid is effectively connected with such a business carried on through that permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall applyestablishment. 5. (8) Where a company which is a resident of a one of the Contracting State States derives profits or income from the other Contracting State, that other Contracting State may not impose any tax on the dividends paid by the company, except insofar as such dividends company to persons who are paid to a resident not residents 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 Contracting State, nor or subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State. (9) If the system of taxation applicable in either Contracting State to the profits or distributions of companies is altered the competent authorities of both Contracting States may consult each other in order to determine whether it is necessary for this reason to amend the provisions of this article.

Dividends. 1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State shall be taxable only in that other State if the recipient of the dividends a) is a company (other than a partnership); b) is the beneficial owner of these dividends, and c) holds directly shares representing at least 25 per cent of the capital and the voting power of the company paying the dividends. 2. Dividends, other than those referred to in paragraph 1, 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 recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) exceed 15 per cent of the gross amount of the dividends in all other casesdividends. This paragraph The competent authorities of the Contracting States may by mutual agreement settle the mode of application of this limitation. 3. Paragraphs 1 and 2 shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 34. The term "dividends" as used in this Article means income from shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 45. 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. 56. 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 Contracting State. 2. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident resident, and according to the laws of that State, but if the recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power capital of the company paying the dividends; (b) 15 10 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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 shares, or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 Contracting 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 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 Contracting 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 Contracting 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

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 recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds controls directly at least 25 per cent of the voting power of in the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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 shares, or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated 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 and also includes any other item (other than interest relieved from tax under Article 11 of this Convention) which, under the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution dividend is a resident, is treated as a dividend or distribution of a company. (4. ) The provisions of paragraphs 1 (1) and 2 (2) of this Article 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 1414 of this Convention, 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such that other State.

Dividends. 128.1. Dividends The Board of Directors may from time declare, and cause the Company to pay, such dividend as may appear to the Board of Directors to be justified by the profits of the Company and as permitted by the Companies Law. The Board of Directors shall determine the time for payment of such dividends and the record date for determining the shareholders entitled thereto. 28.2. Subject to the provisions of these Articles and subject to the rights or conditions attached at that time to any share in the capital of the Company granting preferential, special or deferred rights or not granting any rights with respect to dividends, any dividend paid by a company which is a resident of a Contracting State the Company shall be allocated among the shareholders entitled thereto in proportion to a resident their respective holdings 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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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 or other rights, not being debt-claims, participating in profits and includes any income or distribution assimilated to income from shares under the taxation laws of the Contracting State of which the company paying the dividends or income or 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, that other State may not impose any tax on the dividends paid by the company, except insofar as such dividends are being paid. 28.3. No dividend shall carry interest as against the Company. 28.4. The Board of Directors may determine that the Company (i) may cause any moneys, investments, or other assets forming part of the undivided profits of the Company, standing to the credit of a reserve fund, or to the credit of a reserve fund for the redemption of capital, or in the hands of the Company and available for dividends, or representing premiums received on the issuance of shares and standing to the credit of the share premium account, to be capitalized and distributed among such of the Shareholders as would be entitled to receive the same if distributed by way of dividend and in the same proportion, on the footing that they become entitled thereto as capital; and (ii) may cause such distribution or payment to be accepted by such Shareholders in full satisfaction of their interest in the said capitalized sum. 28.5. All unclaimed dividends or other moneys payable in respect of a share may be invested or otherwise made use of by the Board of Directors for the benefit of the Company until claimed. The payment by the Directors of any unclaimed dividend or such other moneys into a separate account shall not constitute the Company a trustee in respect thereof, and any dividend unclaimed after a period of seven (7) years from the date of declaration of such dividend, and any such other moneys unclaimed after a like period from the date the same were payable, shall be forfeited and shall revert to the Company, provided, however, that the Board of Directors may, at its discretion, cause the Company to pay any such dividend or such other moneys, or any part thereof, to a person who would have been entitled thereto had the same not reverted to the Company. The principal (and only the principal) of any unclaimed dividend of such other moneys shall be, if claimed, paid to a resident of that person entitled thereto. 28.6. Any dividend or other State or insofar as the holding moneys payable in cash in respect of which a share may be paid by check or payment order sent through the dividends are paid is effectively connected with a permanent establishment post to, or a fixed base situated in that other Stateleft at, nor subject the company's undistributed profits registered address of the person entitled thereto or by transfer to a tax on bank account specified by such person (or, if two or more persons are registered as joint holders of such share or are entitled jointly thereto in consequence of the company's undistributed profitsdeath or bankruptcy of the holder or otherwise, even if to the dividends paid joint holder whose name is registered first in the Register or his bank account or the undistributed profits consist wholly person who the Company may then recognize as the owner thereof or partly of profits entitled thereto under these Articles, as applicable, or income arising in such person’s bank account), or to such person and at such other Stateaddress as the person entitled thereto may by writing direct, or in any other manner the Board of Directors deems appropriate. Every such check or warrant or other method of payment shall be made payable to the order of the person to whom it is sent, or to such person as the person entitled thereto as aforesaid may direct, and payment of the check or warrant by the banker upon whom it is drawn shall be a good discharge to the Company. 28.7. If two or more persons are registered as joint holders of any share, or are entitled jointly thereto in consequence of the death or bankruptcy of the holder or otherwise, any one of them may give effectual receipts for any dividend or other moneys payable or property distributable in respect of such share.

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: a) shall be exempt from tax in the Contracting State of which the company paying the dividends is a resident if the beneficial owner of the dividends is: (i) a company which is a resident of the other Contracting State and holds, directly or indirectly, at least 50 per cent of the capital of the company paying the dividends and has invested at least £1 million (or the equivalent amount in any other currency) in the capital of the company paying the dividends at the date of payment of the dividends; or (ii) a pension scheme; b) except as provided in sub-paragraph a), 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: (ai) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds holds, directly or indirectly, at least 25 20 per cent of the voting power capital of the company paying the dividends; (bii) 15 10 per cent of the gross amount of the dividends in all other cases. This The provisions of this paragraph shall 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 shares, or other rights, not being debt-claims, participating in profits and includes profits, as well as any income or distribution assimilated other item which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 baseestablishment. 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 that 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, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such that other State. 6. No relief shall be available under this Article if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the shares or other rights in respect of which the dividend is paid to take advantage of this Article by means of that creation or assignment.

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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 exceed 15 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of paragraph 2, the Contracting State of which the company is a resident shall exempt from tax dividends paid by that company, if the beneficial owner is of the dividends is: a) a company (other than a partnership) which is a resident of the other Contracting State and holds directly at least 25 10 per cent of the voting power capital of the company paying the dividends; (b) 15 per cent dividends throughout a 365 day period that includes the day of the gross amount payment of the dividends in all other cases(for the purpose of computing that period, no account shall be taken of changes of ownership that would directly result from a corporate reorganisation, such as a merger or divisive reorganisation, of the company that holds the shares or that pays the dividend); or b) a pension fund. 4. This paragraph The competent authorities of the Contracting States may by mutual agreement settle the mode of application of paragraphs 2 and 3. 5. The provisions of paragraphs 2 and 3 shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 36. The term "dividends" as used in this Article means income from shares, "jouissance" shares or "jouissance" rights, mining shares, founders' shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 47. The provisions of paragraphs 1 1, 2, 3 and 2 9 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 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, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 58. 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. 9. Notwithstanding the provisions of paragraphs 1, 2 and 8, dividends paid by a company, which under the laws of a Contracting State is a resident of that State, to an individual who is a resident of the other Contracting State and who upon ceasing to be a resident of the first-mentioned State is taxed on the appreciation of capital as meant in paragraph 6 of Article 13, may also be taxed in that State in accordance with the laws of that State, but only for a period of ten years after emigration of the individual and insofar as the assessment on the appreciation of capital is still outstanding.

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 recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 15 per cent of the voting power capital of the company paying the dividends; (b) 10 per cent of the gross amount of the dividends if the beneficial owner is a company which holds directly at least 10 per cent of the capital of the company paying the dividends; (c) 15 per cent of the gross amount of the dividends in all other cases. This The provisions of this paragraph shall 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 or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 a 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

Dividends. 1. Dividends paid by a company which is a resident of a Contracting State Party to a resident of the other Contracting State Party may be taxed in that other StateParty. 2. However, such dividends may also be taxed in the Contracting State Party of which the company paying the dividends is a resident and according to the laws of that StateParty, but if the recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) exceed 15 per cent of the gross amount of the dividends in all other casesdividends. This paragraph shall 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 or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State Party of which the company paying the dividends or income or 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 StateParty, carries on business in the other Contracting State Party of which the company paying the dividends is a resident, through a permanent establishment situated therein, or performs in that other State Party 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 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 Party derives profits or income from the other Contracting StateParty, that other State Party 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 Contracting Party 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 StateParty, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends dividend paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.Party

Dividends. 1. Dividends paid by a company which is a resident of a Contracting State One Side to a resident of the other Contracting State Other Side may be taxed in that other StateOther Side. 2. However, such dividends may also be taxed in the Contracting State Side of which the company paying the dividends is a resident and according to the laws of that StateSide, but if the recipient is the beneficial owner of the dividends is a resident of the other Contracting Statedividends, the tax so charged shall not exceed: (a) 5 exceed 10 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent dividends. The competent authorities of the voting power Two Sides shall by mutual agreement settle the mode of the company paying the dividends; (b) 15 per cent application of the gross amount this limitation. The provisions of the dividends in all other cases. This this paragraph shall 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 shares, or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State Side of which the company paying the dividends or income or 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 StateOne Side, carries on business in the other Contracting State Other Side of which the company paying the dividends is a resident, through a permanent establishment situated therein, or performs in that other State Other Side 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 One Side derives profits or income from the other Contracting StateOther Side, that other State Other Side 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 Other Side 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 StateOther Side, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other StateOther Side.

Dividends. 1. Dividends paid by a company which is a resident of a Contracting State one of the States 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 beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 15 per cent of the gross amount of the dividends if the beneficial owner recipient is a company (other than a partnership) which holds directly at least 25 per cent of the voting power capital of the company paying the dividends; (b) 15 20 per cent of the gross amount of the dividends in all other cases. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. The competent authorities of the States shall by mutual agreement settle the mode of application of paragraph 2. 4. The term "“dividends" ” as used in this Article article means income from shares, “jouissance” shares or “jouissance” rights, founders’ shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 45. Profits from a company of one of the States carrying on business in the other State through a permanent establishment situated therein may, after having been taxed under Article 7, be taxed on the remaining amount in the State in which the permanent establishment is situated and the taxes so charged shall not exceed 50 per cent of the percentage provided for in sub-paragraph (a) of paragraph 2 of this Article. 6. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner recipient of the dividends, being a resident of a Contracting Stateone of the States, 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 or, in the case of a resident of Turkey, performs in that other State the Netherlands independent personal services from a fixed base situated thereinin the Netherlands, 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. 57. Where a company which is a resident of a Contracting State one of the States 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, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

Dividends. 1. Dividends paid by a company which is a resident of a Contracting State Party to a resident of the other Contracting State may be taxed in that other State. 2. HoweverParty shall, such dividends may also be taxed in if the Contracting State of which the company paying the dividends recipient is a resident and according to the laws of that State, but if the beneficial owner of the dividends is a resident of the dividends, be taxable only in that other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paidParty. 32. The term "dividends" as used in this Article means income from shares, “jouissance” shares or “jouissance” rights, mining shares, founders’ shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State Party of which the company paying the dividends or income or making the distribution is a resident. 43. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting StateParty, carries on business in the other Contracting State Party of which the company paying the dividends is a resident, resident through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 54. Where a company which is a resident of a Contracting State Party derives profits or income from the other Contracting StateParty, that other State Party may not impose any tax on the dividends paid by the company, company except insofar in so far as such dividends are paid to a resident of that other State Party or insofar in so far 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 StateParty, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other StateParty.

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 Contracting State. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in the that Contracting State of which the company paying the dividends is a resident and according to the laws of that Contracting 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) 5 exceed 7 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of paragraph 2, dividends if which are deductible in computing the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power taxable income of the company paying the dividends; (b) 15 dividends in the Contracting State of which that company is a resident may be taxed in that Contracting State according to the laws of that Contracting State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the dividends in all other casesdividends. 4. This paragraph The provisions of paragraphs 2 and 3 shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 35. The term "“dividends" ” as used in this Article means income from shares, founders’ shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 46. The provisions of paragraphs 1 1, 2 and 2 3 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, resident through a permanent establishment situated therein, or performs in that other Contracting 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. 57. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other Contracting 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 Contracting 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

Dividends. 1. Dividends paid by a company which is a resident of a Contracting State one of the States 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 paid by a company 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 StateNetherlands to a resident of Singapore may be taxed in the Netherlands, and according to Netherlands law, but the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) exceed 15 per cent of the gross amount of the dividends. Where, however, the recipient of the dividends is a company the capital of which is wholly or partly divided into shares and which holds directly or indirectly at least 25 per cent of the capital of the company paying the dividends, the Netherlands shall not levy a tax on the dividends. 3. Dividends paid by a company which is a resident of Singapore to a resident of the Netherlands shall be exempt from any tax in Singapore which is chargeable on dividends in all other casesaddition to the tax chargeable in respect of the profits of the company. 4. This The provisions of paragraph 2 shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 35. The term "“dividends" ” as used in this Article means income from shares, “jouissance” shares or “jouissance” rights, mining shares, founders' shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution from other corporate rights assimilated to income from shares under by the taxation laws law of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 46. The provisions of paragraphs 1 1, 2 and 2 3 shall not apply if the beneficial owner recipient of the dividends, being a resident of a Contracting Stateone of the States, carries on business has in the other Contracting State 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 with which the holding in respect by virtue of which the dividends are paid is effectively connected with such permanent establishment or fixed baseconnected. In such case a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 57. Where a company which is a resident of a Contracting State one of the States 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 company to persons who are paid to a resident not residents 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, nor or subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. 8. If the system of taxation applicable in either of the States to the profits and distributions of companies is substantially altered the competent authorities may consult each other in order to determine whether it is necessary for this reason to amend the provisions of paragraphs 1, 2 and 3 of this Article.

Dividends. 1. Dividends paid by a company which is a resident of a Contracting State one of the States 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 recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 10 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power capital of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. 3. This The provisions of paragraph (2) shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 34. The term "‘dividends" ’ as used in this Article means income from shares, ‘jouissance’ rights, mining shares, founders’ shares or other rights, not being debt-claims, rights participating in profits profits, as well as income from profit sharing bonds and includes any income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 45. The provisions of paragraphs 1 (1) and 2 (2) shall not apply if the beneficial owner of the dividends, being a resident of a Contracting Stateone of the States, 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. 56. Where a company which is a resident of a Contracting State one of the States 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, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

Dividends. 1. Dividends paid by a company which 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 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) 5 10 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds that controls directly or indirectly at least 25 10 per cent of the voting power of in the company paying the dividends;; and (b) 15 per cent of the gross amount of the dividends dividends, in all other cases. This The provisions of this paragraph shall 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 or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 4. The provisions of paragraphs 1 and paragraph 2 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on or has carried 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 or has performed 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 that 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. 6. Nothing in this Convention shall be construed as preventing a Contracting State from imposing on the earnings of a company attributable to a permanent establishment in that State, or the earnings attributable to the alienation of immovable property situated in that State by a company carrying on a trade in immovable property, a tax in addition to the tax that would be chargeable on the earnings of a company that is a national of that State, except that any additional tax so imposed shall not exceed 10 per cent of the amount of such earnings that have not been subjected to such additional tax in previous taxation years. For the purpose of this provision, the term "earnings" means the earnings attributable to the alienation of such immovable property situated in a Contracting State as may be taxed by that State under the provisions of Article 6 or of paragraph 1 of Article 13, and the profits, including any gains, attributable to a permanent establishment in a Contracting State in a year and previous years, after deducting therefrom all taxes, other than the additional tax referred to herein, imposed on such profits in that State. 7. The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the shares or other rights in respect of which the dividend is paid to take advantage of this Article by means of that creation or assignment.

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 Contracting 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) 5 exceed 10 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall 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, mining shares, founders’ shares or other rights, not being debt-debt claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 Contracting 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 1415, 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 Contracting State may not impose any tax on the dividends paid by the company, except insofar in so far as such dividends are paid to a resident of that other Contracting State or insofar in so far 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 Contracting State, nor subject the company's ’s undistributed profits to a tax on the company's ’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other Contracting State.

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 resident, and according to the laws law 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) 5 per cent 10% of the gross amount of the dividends if the beneficial owner recipient is a company (other than a excluding partnership) which holds directly at least 25 per cent 25% of the voting power capital of the company paying the dividends; (b) 15 per cent in all other cases, 20% of the gross amount of the dividends in all other casesdividends. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. This paragraph shall 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 or shares, as well as income from other rights, not being debt-claims, participating in profits and includes any income or distribution corporate rights assimilated to income from shares under by the taxation laws law of the Contracting State of which the company paying the dividends or income or making the distribution is a resident. 4. The provisions of paragraphs 1 (1) and 2 (2) shall not apply if the beneficial owner recipient of the dividends, dividends being a resident of a Contracting State, carries on business has in the other Contracting State 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 with which the holding in respect by virtue of which the dividends are paid is effectively connected with such permanent establishment or fixed baseconnected. In such a case the provisions of Article 7 or Article 14, as the case may be, shall applydividends are taxable in that other Contracting State according to its own law. 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 company to persons who are paid to a resident not residents 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, nor or subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. 6. Where a company which is a resident of one of the Contracting States having a permanent establishment in the other Contracting State, derives profits or income from that permanent establishment, any remittances of such profits by the permanent establishment to a resident of the other Contracting State may be taxed in accordance with the law of the first-mentioned Contracting State, but the rate of tax imposed on such remittances shall not exceed 8%.

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 resident, and according to the laws of that State, but if the recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent exceed 10% of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent dividends. The provisions of the voting power of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This this paragraph shall 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 the Article means income from shares, "jouissance" shares or "jouissance" rights, mining shares, founders' shares or other rights, not being debt-claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws law of the Contracting State of which the company paying the dividends or income or 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, therein or performs in that other State independent personal services from a fixed base situated therein, 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 State, derives profits or income from the other Contracting State, 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

Dividends. 1. Dividends paid by a company which is a resident of in a Contracting State to a resident of the other Contracting State may be taxed in that other State. 2. However2nd Notwithstanding the provisions of paragraph 1 may, such however, dividends may also be are 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 recipient of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 exceed 15 per cent of the gross amount of amount. If the dividends if person entitled to the beneficial owner investigation is a company (other than a partnership) which holds directly holding at least 25 per cent percent of the voting power company making the payment, exempt dividends from taxation in the State of which the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other casesis a resident. This paragraph shall not affect the taxation of the company in respect of the company's taxable profits out of which the dividends are paid. 3. third The term "dividends" as used in this Article means income from shares or other rights, not being debt-claims, participating in profits and includes any income or distribution assimilated to profits, as well as income from shares other corporate rights in a company under the taxation laws of the Contracting State of in which the distributing company paying is resident for tax purposes is treated in the dividends or same way as income or making the distribution is a resident. 4from shares. 4th The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being dividends is 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. 5th 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 lasted device in that other this State, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

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 recipient is the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the voting power of the company paying the dividends; (b) 15 exceed fifteen per cent of the gross amount of the dividends in all other cases. This paragraph shall 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 rights”, mining shares, founders shares or other rights, not being debt-debt claims, participating in profits and includes any profits, as well as income or distribution assimilated from other corporate rights which is subjected to the same taxation treatment as income from shares under by the taxation laws of the Contracting State of which the company paying the dividends or income or 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 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 article 7 or Article 14, 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 in so far as such dividends are paid to a resident of that other State or insofar in so far 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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.the