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 Contracting State. 2. However, dividends paid by a company which is a resident of a Contracting State may also 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. 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 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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, as well as income from other rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 7. The provisions of paragraphs 1, 2 and 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 and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply. 8. 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 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 that 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 10 5 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 that 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 10 5 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 The competent authorities of the dividends is a resident Contracting States shall by mutual agreement settle the mode of that other Contracting State and is either: (a) a company which has owned directly or indirectly, for the period application of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power of the company paying the dividends; or (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of this limitation. This 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. 5. 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. 63. The term "dividends" as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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, dividends paid by a company which is a resident of a Contracting State may also 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 exceed: (a) 5 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: (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 dividends is a resident of Morocco, the capital of that company; (b) 10 per cent of the gross amount of the dividendsdividends in all other cases. 3. Notwithstanding the provisions of paragraph 2, dividends paid by a 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 of a may be taxed in that Contracting State shall be taxable only in according to the other laws of that Contracting State State, but if the beneficial owner of the dividends is a resident of that the other Contracting State and is either: (a) a company which has owned directly or indirectlyState, for the period of six months ending on the date on which entitlement to the dividends is determined, at least tax so charged shall not exceed 10 per cent of the voting power gross amount of the company paying the dividends; 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. 5. 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, “jouissance” shares or “jouissance” rights, mining shares, founders’ shares or other rights, not being debt-claims, participating in profits, as well as other income from other rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 76. The provisions of paragraphs 1, 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 87. 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 that 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 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 capital of the company paying the dividends; (b) 10 per cent of the gross amount of the dividends. 3dividends in all other cases. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 Party to a resident of the other Contracting State Party, may be taxed in that other Contracting StateParty. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in that the Contracting State Party of which the company paying the dividends is a resident, and according to the laws of that Contracting StateParty, but if the beneficial owner of the dividends is a resident of the other Contracting StateParty, the tax so charged shall not exceed 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares, founders’ shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State Party of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 3 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 therein, or performs in that other 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 Contracting 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 Contracting 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 Contracting 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 income or profits or income arising in such other Contracting 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 that the Contracting State of which the company paying the dividends is a resident, and according to the laws of that Contracting 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 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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, dividends paid by a company which is a resident of a Contracting State may also 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 5 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 which has owned directly or indirectly, for the period of six months ending on the date on which entitlement to the dividends is determined, indirectly at least 10 25 per cent of the voting power of the company paying the dividends; or dividends throughout a 365 day period that includes the date on which entitlement to the dividends is determined (b) for the purpose of computing that period, no account shall be taken of changes of ownership that would directly result from a pension fundcorporate reorganisation, 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 as a merger or divisive reorganisation, of the company in respect of the profits out of which the dividends are paid. 5. The provisions of subparagraph (a) of paragraph 3 shall not apply in the case of dividends paid by a company which that 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, as well as income from other rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 7. The provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the dividends or that pays the dividends). (a) A company, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is shall not be entitled to a resident through a permanent establishment situated therein and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment. In such case benefit that would otherwise be accorded under the provisions of Article 7 shall applyparagraph 3 unless such company is a qualified person, as defined in subparagraph (b), at the time when the benefit would otherwise be accorded. 8. Where a company which is (b) A company, being a resident of a Contracting State, shall be a qualified person at a time when a benefit referred to in subparagraph (a) would otherwise be accorded if: (i) at that time, the principal class of its shares is regularly traded on one or more recognised stock exchanges; or (ii) at that time and on at least half of the days of a twelve month period that includes that time, at least 50 per cent of its shares are directly or indirectly owned by a person or persons who is a resident of that Contracting State derives profits and is: (aa) a company which satisfies the requirement described in clause (i); (bb) an individual; or (cc) that Contracting State, a political subdivision or income from local authority thereof, the central bank of that Contracting State, or an agency or instrumentality of that Contracting State or political subdivision or local authority. (c) If a company, being a resident of a Contracting State, is not a qualified person, the competent authority of the Contracting State in which a benefit is denied under subparagraph (a) may, nevertheless, grant a benefit referred to in that subparagraph, taking into account the object and purpose of the Agreement, but only if such company demonstrates to the satisfaction of such competent authority that neither its establishment, acquisition or maintenance, nor the conduct of its operations, had as one of its principal purposes the obtaining of such benefit. The competent authority of the Contracting State to which a request has been made under this subparagraph by a company, being a resident of the other Contracting State, that other Contracting State may not impose any tax on shall consult with the dividends paid by the company, except insofar as such dividends are paid to a resident competent authority of that other Contracting State before either granting or insofar as denying the holding in respect request. (d) For the purposes of which the dividends are paid is effectively connected with a permanent establishment 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.this paragraph:

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 that 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 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 10 5 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 15, as the case may be, shall apply., 85. 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 paid by a company which is a resident of a Contracting State may also be taxed in that the Contracting State of which the company paying the dividends is a resident, and according to the laws law 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 10 per cent - (a) 15 percent of the gross amount of the dividends. 3. Notwithstanding dividends if the provisions of paragraph 2, dividends paid by recipient is a company which is a resident of a Contracting State shall be taxable only in (including partnership) and during the other Contracting State if the beneficial owner part of the dividends is a resident of that other Contracting State and is either: (a) a company paying company's taxable year which has owned directly or indirectly, for the period of six months ending on precedes the date on which entitlement to of payment of the dividends is determineddividend and during the whole of its prior taxable year (if any), at least 10 per cent 15 percent of the outstanding shares of the voting power stock of the paying company paying was owned by the dividendsrecipient company; orand (b) a pension fund, provided that such dividends are derived from in all other cases 25 percent of the activities referred to in clause (ii) gross amounts of subparagraph (l) the dividends. The competent authorities of paragraph 1 the Contracting States shall by mutual agreement settle the mode of Article 3application of this limitation. 43. The provisions of paragraphs 1 and 2 and 3 shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 64. 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, as well as income from other rights which is subjected assimilated to the same taxation treatment as income from shares by the laws taxation law of the Contracting State of which the company making the distribution is a resident. 75. The provisions of paragraphs 1, 1 and 2 and 3 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 resident, trade or business through a permanent establishment situated therein therein, or performs in that other State 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 establishmentestablishment or fixed base. In such case a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 86. Where a company which is a resident of a Contracting State derives derived profits or income from the other Contracting State, that other Contracting 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 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 dividend is a resident of the other Contracting State, the tax so charged shall not exceed 10 exceed: (a) 4 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 company (other Contracting State and is either: (athan a partnership) a company which has owned holds directly or indirectly, for the period of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power capital of the company paying the dividends; or; (b) a pension fund, provided that such 5 per cent of the gross amount of the dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of all other cases. This 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. 5. 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. 63. 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, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 ’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 provision 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 taxable under article 7, paragraph 1, may be subject to an additional tax in that other State, in accordance with its laws, but the additional charge shall not exceed 4 per cent of the amount of 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 Contracting State. 2. However, dividends paid by a company which is a resident of a Contracting State may also 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 5 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of paragraph 2, dividends paid by a 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 of a may be taxed in that Contracting State shall be taxable only in according to the other laws of that Contracting State State, but if the beneficial owner of the dividends is a resident of that the other Contracting State and is either: (a) a company which has owned directly or indirectlyState, for the period of six months ending on the date on which entitlement to the dividends is determined, at least tax so charged shall not exceed 10 per cent of the voting power gross amount of the company paying the dividends; 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. 5. 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, mining shares, founders’ shares or other rights, not being debt-claims, participating in profits, as well as income from other rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 76. The provisions of paragraphs 1, 2 and 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 and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply. 87. 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 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 that 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 10 % (ten per cent cent) of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 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 capital of the company paying the dividends; (b) 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 all 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 10 per cent of the voting power of the company paying the dividends; 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. 4cases. The provisions of paragraphs 2 and 3 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 3 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 therein, or performs in that 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14 of this Agreement, as the case may be, shall apply. 85. 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 Party to a resident of the other Contracting State may be taxed in that other Contracting State. 2. However, dividends paid by a company which is a resident of a Contracting State may also 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. 3. Notwithstanding the provisions of paragraph 2, dividends paid by a company which is a resident of a Contracting State Party 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 10 per cent of the voting power of the company paying the dividends; or (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of Party. This 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. 5. 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. 62. 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, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State Party of which the company making the distribution is a resident. 73. The provisions of paragraphs 1, 2 and 3 paragraph 1 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 therein, or performs in that other 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 84. Where a company which is a resident of a Contracting State Party derives profits or income from the other Contracting StateParty, that other Contracting 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 Contracting 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 Contracting StateParty, 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 Contracting 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 that 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 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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 the other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 State, of which the company paying the dividends is a resident resident, through a permanent establishment situated therein therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment. In such case a case, the provisions of Article 7 shall apply. 85. Where a company which is a resident of a Contracting State derives income or 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 Contracting State or insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment situated in that other Contracting State, nor or 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, 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 that 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 Statedividends, the tax so charged shall not exceed 10 per cent 5 percent 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 The competent authorities of the dividends is a resident Contracting States shall by mutual agreement settle the mode of that other Contracting State and is either: (a) a company which has owned directly or indirectly, for the period application of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power of the company paying the dividends; or (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of this limitation. This 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. 5. 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. 63. The term "dividends" as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the ease may be, shall apply. 85. 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 that 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 10 5 per cent of the gross amount of the dividends. 3dividends in all cases. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 53. The Notwithstanding the provisions of subparagraph (a) paragraph 2, dividends arising in a Contracting State and paid to, and beneficially owned by, the Government of paragraph 3 the other Contracting State shall not apply be exempt from tax 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 residentfirst-mentioned State. 64. 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, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 75. The provisions of paragraphs 1, 1 and 2 and 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 and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment. In such case case, the provisions of Article 7 shall apply. 86. 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 situated in that other Contracting 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 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 that 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 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 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 Contracting State. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in that 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 10 per cent 17 percent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "“dividends" as used ” in this Article means income from shares or and other rights, not being debt-claims, participating in profits, as well as income from other rights which is subjected assimilated to the same taxation treatment as income from shares by the laws law relating to tax, of the Contracting State of which the company making the distribution is a residentresident for the purposes of its tax. 74. The provisions of paragraphs 1, 1 and 2 and 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 therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such case case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 85. 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 undistributed ’s undistribued 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 that 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 10 per cent 10% of the gross amount of the such 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. 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, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14,as the case may be, shall apply. 85. 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 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 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 Contracting State. 2. However, subject to the agreed Protocol, such dividends paid by a company which is a resident of a Contracting State may also be taxed in that 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 10 15 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-debt claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 therein, or performs in that 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 establishmentestablishment or fixed base. In such case case, the provisions of Article 7 or Article 14,as the case may be, shall apply. 85. 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 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. 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 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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 residentresident and according to the laws of that State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company which controls, directly or indirectly, at least 10 per cent of the voting power in the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. The provisions of this paragraph shall not affect the taxation of the company on the profits out of which the dividends are paid. 6(3) 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 the United Kingdom 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. However, when Singapore imposes a tax on dividends in addition to the tax chargeable on the profits or income of a company, the rates as prescribed under the provisions of paragraph 2 of this Article shall apply. (4) The term "dividends" as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected assimilated to the same taxation treatment as income from shares by the taxation laws of the State of which the company making the distribution is a resident and also includes any other item which, under the laws of the Contracting State of which the company making paying the distribution dividends is a resident, is treated as a dividend or distribution of a company. 7. (5) The provisions of paragraphs 1, 1 and 2 and 3 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14 of this Agreement, as the case may be, shall apply. 8. (6) 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 that other 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. (8) In the event that a resident of a Contracting State is denied relief from taxation in the other Contracting State by reason of the provisions of paragraph 7 of this Article, the competent authority of the other Contracting State shall notify the competent authority of the first-mentioned 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 that 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 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 The competent authorities of the dividends is a resident Contracting States shall by mutual agreement settle the mode of that other Contracting State and is either: (a) a company which has owned directly or indirectly, for the period application of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power of the company paying the dividends; or (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of this limitation. This 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. 5. 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. 63. The term "dividends" as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. The term also includes profits attributed under an arrangement for participation in profits ("associacao em participacao"). 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 shall, if the recipient is the beneficial owner of the dividends, be taxed taxable only in that other Contracting State. 2. However, dividends paid by a company which is a resident of a Contracting State may also 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. 3. Notwithstanding the 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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 assimilated to the same taxation treatment as income from shares by according to the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 2 and 3 paragraph 1 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 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. 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 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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 residentresident and according to the laws of that State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed: (a) 5% of the gross amount of the dividends if the beneficial owner has contributed, directly or indirectly, more than 50% of the 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; (c) 12.5% of the gross amount of the dividends in all other cases. 63. 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, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 76. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 87. 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 that other Contracting 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 Statedividends, the tax so charged shall not exceed 10 per cent 10% of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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 assimilated to the same taxation treatment as income from shares by according to the taxation laws of the Contracting State of which the company making the distribution is a resident. 74. 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 Poland 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. 5. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 86. 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. (a) Dividends shall be deemed to arise in Poland if they are paid by a company which is a resident of Poland. (b) Dividends shall be deemed to arise in Singapore - (i) if they are paid by a company which is a resident of Singapore; or (ii) if they are paid by a company which is a resident of Malaysia out of profits arising in Singapore and qualifying as dividends arising in Singapore under Article VII of the Agreement for the Avoidance of Double Taxation between Singapore and Malaysia signed on 26th December, 1968. 8. The Government of either Contracting State shall be exempt from tax in the other Contracting State with respect to dividends on shares in joint stock companies of that other State. However, such exemption shall in no case be given with respect to shares held for other than public purposes and not if the holding constitutes a substantial participation. 9. For the purpose of paragraph 8, the term "Government": (a) in the case of Singapore means the Government of Singapore, and shall include: (i) the Monetary Authority of Singapore and the Board of Commissioners of Currency; (ii) the Government of Singapore Investment Corporation Pte Ltd and any company or body established wholly for the purpose of investing the reserves of the Government; (iii) a statutory body, a local authority or any institution wholly or mainly owned by the Government of Singapore, as may be agreed from time to time between the competent authorities of the Contracting States; (b) in the case of Poland means the Government of Poland, and shall include: (i) The National Bank of Poland; (ii) a statutory body, a local authority or any institution wholly or mainly owned by the Government of Poland, as may be agreed from time to time between the competent authorities of the Contracting States.

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 that 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 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 3 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14 of this Agreement, as the case may be, shall apply. 85. 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, dividends paid by a company which is a resident of a Contracting State may also 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. 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 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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, as well as income from other rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 7. The provisions of paragraphs 1, 2 and 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 and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply. 8. 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 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 that 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 10 (7) seven per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case case, the provisions of Article 7 or 14 shall apply, as the case may be. 85. 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 situated in that other Contracting 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 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 that 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 10 5 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 The competent authorities of the dividends is a resident Contracting States shall by mutual agreement settle the mode of that other Contracting State and is either: (a) a company which has owned directly or indirectly, for the period application of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power of the company paying the dividends; or (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of this limitation. This 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. 5. 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. 63. 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, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 Statedividends, the tax so charged shall be calculated at a rate not exceed exceeding: (a) 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 which has owned directly or indirectly, for the period of six months ending on the date on which entitlement to the dividends is determined, holds at least 10 25 per cent of the voting power capital of the company paying the dividends; or (b) a pension fund, provided that such 15 per cent of the gross amount of the dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of all other cases. This 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. 5. 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. 63. The term "dividends" as used in this Article means income from shares or other rights, rights participating in profits (not being debt-debt claims, participating in profits), as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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, 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 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 Contracting State. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in that 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 10 5 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 The competent authorities of the dividends is a resident Contracting States shall by mutual agreement settle the mode of that other Contracting State and is either: (a) a company which has owned directly or indirectly, for the period application of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power of the company paying the dividends; or (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of this limitation. This 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-debt claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14,as the case may be, shall apply. 85. 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 company′s undistributed profits to a tax on the company's 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 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 capital of the company paying the dividends; (b) 10 per cent of the gross amount of the dividends. 3dividends in all other cases. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 that 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 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 capital of the company paying the dividends; (b) 10 per cent of the gross amount of the dividends. 3dividends in all other cases. 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 The competent authorities of the dividends is a resident Contracting States shall by mutual agreement settle the mode of that other Contracting State and is either: (a) a company which has owned directly or indirectly, for the period application of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power of the company paying the dividends; 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. 4this limitation. The provisions of paragraphs 2 and 3 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 that 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 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 capital of the company paying the dividends; (b) 10 per cent of the gross amount of the dividends. 3dividends in all other cases. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 that 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 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 capital of the company paying the dividends; (b) 10 per cent of the gross amount of the dividends. 3dividends in all other cases. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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, dividends Dividends paid by a company which is a resident of Sweden to a Contracting State resident of Malaysia may also be taxed in that Contracting State Sweden according to the laws of that Contracting StateSwedish laws, 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 10 15 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of paragraph 2Where, dividends paid by a company which is a resident of a Contracting State shall be taxable only in the other Contracting State if however, the beneficial owner of the dividends is a resident of that company (other Contracting State and is either: (athan a partnership) a company which has owned holds directly or indirectly, for the period of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power of the company paying the dividends; or, the dividends shall be exempt from tax in Sweden. (b) 3. Dividends paid by a pension fund, provided that such company which is a resident of Malaysia to a resident of Sweden who is the beneficial owner thereof shall be exempt from any tax in Malaysia which is chargeable on dividends are derived from in addition to the activities referred to tax chargeable in clause (ii) respect of subparagraph (l) income or profits of paragraph 1 of Article 3the company. 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. 5. 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, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 76. The provisions of paragraphs 1, 2 and 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 State, of which the company paying the dividends is a resident 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 15, as the case may be, shall apply. 87. Where a company which is a resident of a Contracting State derives income or 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 income or 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 that 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 10 5 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions provision of paragraphs 1, 1 and 2 and 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 therein, or performs in that 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 the 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 that 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 10 15 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 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 to a resident of the other Contracting State shall be taxable only in the that other Contracting State if the beneficial owner of the dividends is a resident of that company (other Contracting State and is either: (athan a partnership) a company which has owned holds directly or indirectly, for the period of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power capital of the company paying the dividends; 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 competent authorities of the Contracting States shall by mutual agreement settle the mode of application of the limitations of the provisions of paragraphs 2 and 3 3. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 64. 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, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 75. The provisions of paragraphs 1, 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 86. 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 that 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 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "dividends" as used in this Article means income from shares or other rights, not being debt-debt claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 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 The competent authorities of the dividends is a resident Contracting States shall by mutual agreement settle the mode of that other Contracting State and is either: (a) a company which has owned directly or indirectly, for the period application of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power of the company paying the dividends; or (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of this limitation. This 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. 5. 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. 63. 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, as well as income from the other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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, 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 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. (a) Under the current domestic laws of both Contracting States, where dividends are paid by a company which is a resident of one Contracting State to a resident of the other Contracting State who is the beneficial owner of such dividends, there is no tax chargeable on dividends in addition to the tax chargeable in respect of the profits or income of the company. Under the full imputation system currently adopted in Singapore up to 31st December 2007, the tax deductible from dividends is a tax on the profits or income of the company and not a tax on dividends within the meaning of this Article. (b) If, subsequent to the signing of this Agreement, either Contracting State imposes a tax on dividends in addition to the tax chargeable in respect of the profits or income of a company which is a resident of that Contracting State, such tax may be charged but the tax so charged on the dividends derived by a resident of the other Contracting State who is the beneficial owner of such dividends shall be in accordance with the provisions of paragraph 2.

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 Contracting StateParty. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in that the Contracting State Party of which the company paying the dividends is a resident and according to the laws of that Contracting 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 10 15 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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 laws of the Contracting State Party of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 3 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 therein, or performs in that other 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 establishmentestablishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. Where a company which is a resident of a Contracting State Party derives profits or income from the other Contracting StateParty, that other Contracting 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 Contracting 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 Contracting 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 Contracting State.Party

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 that 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 10 exceed: (a) 15 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of paragraph 2, dividends where qualifying dividends are 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:property investment vehicle; (ab) 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 10 5 per cent of the voting power gross amount of the company paying the dividends; ordividends in all other cases. (b3) 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. 5. 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 shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company 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. 7. (4) The provisions of paragraphs (1, 2 ) and 3 (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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14 as the case may be of this Convention, shall apply. 8. (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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 10 per cent percent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 or other corporate rights in respect of which the dividends are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such case the provisions of Article 7 or 13, as the case may be, shall apply. 85. 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 or other corporate rights 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 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 Contracting State. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in that 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 10 15 per cent of the gross amount of the dividends. The competent authorities of the Contracting States may by mutual agreement settle the mode of application of this limitation. 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 Paragraphs 1 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 64. 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 laws of the Contracting State of which the company making the distribution is a resident. 75. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 86. 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 10 per cent exceed; (i) 15 percent 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 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 10 per cent of the voting power of the company paying the dividends; ordividends engages in an industrial undertaking; (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) 20 percent of subparagraph (l) the gross amount of the dividends in other case. This 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares, mining shares, founders’ shares or other rights, rights (not being debt-debt- claims), participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 income or profits or income arising in such other State. 6. Notwithstanding the provisions of paragraph 5, where a company which is a resident of a Contracting State has a permanent establishment in the other Contracting State, the profits of this permanent establishment may, after having borne the corporation tax, be liable to a tax according to the laws of 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 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 share capital of the company paying the dividends; (b) 10 per cent of the gross amount of the dividends. 3dividends in all other cases. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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 in the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply. 85. Where a company which is a resident of a Contracting State derives income or 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 Contracting State or insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment 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 income or 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, dividends paid by a company which is a resident of a Contracting State may also 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 exceed: (a) 8% of the gross amount of the dividends, except as provided for in subparagraph (b); (b) 15% of the gross amount of the dividends, where dividends are paid by an Irish Real Estate Investment Trust (REIT). 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 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 eitherto: (a) a company which has owned directly or indirectlyin the case of Kenya, for the period Central Bank of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power of the company paying the dividends; orKenya; (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. 5. The provisions of subparagraph (a) of paragraph 3 shall not apply in the case of dividends paid Ireland, the Central Bank of Ireland and the National Treasury Management Agency or the bodies under its management; (c) any other statutory body or institution wholly owned by a company which is entitled the Government of either Contracting State, as may be agreed from time to a deduction for dividends paid to its beneficiaries in computing its taxable income in time between the competent authorities of the Contracting State of which the company paying the dividends is a residentStates, shall be exempt from tax in that Contracting State. 64. 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 laws of the Contracting State of which the company making the distribution is a resident. 75. The provisions of paragraphs 1, 1 and 2 and 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 and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply. 86. 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 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 exceed: (a) 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 which has owned directly or indirectly, for the period of six months ending on the date on which entitlement to the dividends is determined, holds at least 10 per cent of the voting power capital of the company paying the dividends; or (b) a pension fund, provided that such 15 per cent of the gross amount of the dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of paragraph 1 of Article 3. 4all other cases. The provisions competent authorities of paragraphs 2 and 3 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. 5. 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. 63. 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), as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 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 resedent 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 that the Contracting State of which the cpmpany 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) 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 which has owned directly or indirectly, for the period of six months ending on the date on which entitlement to the dividends is determined, holds at least 10 per cent percent of the voting power capital of the company paying the dividends; or (b) a pension fund, provided that such 15 per cent of the gross amount of the dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of paragraph 1 of Article 3. 4all other cases. The provisions competent authorities of paragraphs 2 and 3 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. 5. 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. 63. The term "dividends" dividends as used in this Article means income from shares or other rights, rights participating in profits (not being debt-claims, participating in profits), as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 establisment situated therein therein, or performs in that other State independent personal servies from a fixed base situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 undistributed profits, profits even if the dividends paid or the undistributed profits profitd 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 that 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 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 3 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14 of this Agreement, as the case may be, shall apply. 85. 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 that 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 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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, dividends paid by a company which is a resident of a Contracting State such dividend may also be taxed in that the Contracting State of which the company paying the dividends is a residnet, 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 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 10 exceed: (a) 5 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 company that other Contracting State and is either: (a) a company which has owned directly or indirectlydirectly, for the period of six months ending on the date on which entitlement to the dividends is determined, at least 10 25 per cent of the voting power of in the company paying the dividends; or (b) a pension fund, provided that such 15 per cent of the gross amount of the dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of paragraph 1 of Article 3. 4all other cases. The provisions of paragraphs 2 and 3 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 53. The Notwithstanding the provisions of subparagraph (a) of paragraph 3 2, such dividends 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 be taxed in the Contracting State of which the company paying the dividends is a residentresident 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. 64. 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, as well as income from other rights which is subjected to the same taxation treatment as income from shares by the tax laws of the Contracting State of which the company making the distribution is a resident. 76. The provisions of paragraphs 1, 2 and 3 1 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 87. 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 that 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 10 exceed: (a) five 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 company (other Contracting State and is either: (athan a partnership) a company which has owned holds directly or indirectly, for the period of six months ending on the date on which entitlement to the dividends is determined, at least 10 ten per cent of the voting power capital of the company paying the dividends; or; (b) a pension fund, provided that such ten per cent of the gross amount of the dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of all other cases. This 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. 5. 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. 63. 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 10 5 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. 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, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 Contracting State. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in that 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, State the tax so charged shall not exceed 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares or other rightsrights to participate in profits, not being debt-claims, participating in profits, as well as other income from other rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 undistributed profitstax, 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 that 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 Statedividends, the tax so charged to the beneficial owner shall not exceed exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company which holds at least 10 per cent of the capital of the company paying the dividends; (b) 10 per cent of the gross amount of the dividends. 3dividends in all other cases. 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 The competent authorities of the dividends is a resident Contracting States shall by mutual agreement settle the mode of that other Contracting State and is either: (a) a company which has owned directly or indirectly, for the period application of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power of the company paying the dividends; or (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of these limitations. This 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares or other rights, rights (not being debt-claims, ) participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 3 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 and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment. In such case case, the provisions of Article 7 shall apply. 85. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, no tax may be imposed on the beneficial owner in that other Contracting State 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 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 situated in that other Contracting 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 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 that 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 10 5 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. The term "dividends" as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 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 The competent authorities of the dividends is a resident Contracting States shall by mutual agreement settle the mode of that other Contracting State and is either: (a) a company which has owned directly or indirectly, for the period application of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power of the company paying the dividends; or (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of this limitation. This 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-debt claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14,as the case may be, shall apply. 85. 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 company′s undistributed profits to a tax on the company's 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. Nothing in this Agreement shall be construed as preventing a Contracting State from imposing a branch tax on the profits of a company attributable to a permanent establishment in that State, in addition to the tax on profits, provided that branch tax shall not exceed 5 per cent of the amount of such profits which have not been subjected to such branch tax in previous taxation years. For the purpose of this provision, the profits shall be determined after deducting there from all taxes, other than the branch tax referred to in this paragraph, imposed in the Contracting State in which the permanent establishment exists.

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 that 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 10 15 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected subject to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 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. 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 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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, and according to the law of that State, but the tax so charged shall be limited pursuant to the provisions of subparagraphs (a) and (b): (a) dividends paid by a company which is a resident of Ireland to a resident of Luxembourg shall be exempt from Irish sur-tax; (b) dividends paid by a company which is a resident of Luxembourg to a resident of Ireland may be taxed in Luxembourg, but the tax so charged shall not exceed: (i) 5 per cent of the gross amount of the dividends if the recipient is a company (excluding a partnership) which controls directly at least 25 per cent of the voting power in the company paying the dividends; (ii) in all other cases, 15 per cent of the gross amount of the dividends. 63. 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, profits as well as income from other corporate rights which is subjected assimilated to the same taxation treatment as income from shares by the laws taxation law of the Contracting State of which the company making the distribution is a residentresident and, in the case of Luxembourg, the income derived by a sleeping partner from his participation as such. 74. The provisions of paragraphs 1, 1 and 2 and 3 shall not apply if the beneficial owner recipient of the 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 resident, a permanent establishment situated therein and with which the holding in respect by virtue of which the dividends are paid is effectively connected with such permanent establishmentconnected. In such case a case, the dividends shall remain taxable in that other State according to its own law, due regard being had to the other provisions of Article 7 shall applythis Convention. 85. 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 company to persons who are paid to a resident not residents 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 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.

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 that 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 10 per cent 15 percent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. Where a company which is a resident of a Contracting State derives income or 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 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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, State the tax so charged shall not exceed exceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company which holds directly at least 25 per cent of the capital of the company paying the dividends; (b) 10 per cent of the gross amount of the dividends. 3dividends in all other cases. 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 The competent authorities of the dividends is a resident Contracting States shall by mutual agreement settle the mode of that other Contracting State and is either: (a) a company which has owned directly or indirectly, for the period application of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power of the company paying the dividends; or (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of these limitations. This 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. 5. 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. 63. 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 rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 consists 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 that 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 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 The competent authorities of the dividends is a resident Contracting States shall by mutual agreement settle the mode of that other Contracting State and is either: (a) a company which has owned directly or indirectly, for the period application of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power of the company paying the dividends; or (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of these limitations. This 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. 5. 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. 63. 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, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 10 five 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 15, as the case may be, shall apply. 85. 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 that 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. 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 Contracting State. 2. However, dividends paid by a company which is a resident of a Contracting State may also 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 5 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of paragraph 2, dividends paid by a 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 of a may be taxed in that Contracting State shall be taxable only in according to the other laws of that Contracting State State, but if the beneficial owner of the dividends is a resident of that the other Contracting State and is either: (a) a company which has owned directly or indirectlyState, for the period of six months ending on the date on which entitlement to the dividends is determined, at least tax so charged shall not exceed 10 per cent of the voting power gross amount of the company paying the dividends; 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. 5. 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, “jouissance” shares or “jouissance” rights, mining shares, founders’ shares or other rights, not being debt-claims, participating in profits, as well as income from other rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 76. The provisions of paragraphs 1, 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 87. 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 that 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 10 per cent 5 percent 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 The competent authorities of the dividends is a resident Contracting States may by mutual agreement settle the mode of that other Contracting State and is either: (a) a company which has owned directly or indirectly, for the period application of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power of the company paying the dividends; or (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of this limitation. This 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. 5. 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. 63. 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, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, paragraph 1 and 2 and 3 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14 of this Convention, as the case may be, shall apply. 85. 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 that 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 Statedividends, the tax so charged shall not exceed 10 5% per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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: (a) shall be exempt from tax in the Contracting State of which the company paying the dividends paid by is a resident if the beneficial owner of the dividends is a company which is a resident of a the other Contracting State and controls, directly or indirectly, at least 10 per cent. of the voting power in the company paying the dividends; (b) except as provided in sub-pararaph (a) of this paragraph, may also be taxed in that 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 10 15 per cent 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 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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 shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident and also includes any other item which, under the laws of the Contracting State of which the company paying the dividend is a resident, is treated as a dividend or distribution of a company. 7. (4) The provisions of paragraphs (1, 2 ) and 3 (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 therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment. In such case case, the provisions of Article 7 of this Convention shall apply. 8. (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 situated in that other Contracting 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 Contracting 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 Contracting State. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in that 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 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 The competent authorities of the dividends is a resident Contracting States shall by mutual agreement settle the mode of that other Contracting State and is either: (a) a company which has owned directly or indirectly, for the period application of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power of the company paying the dividends; or (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of this limitation. This 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. 5. 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. 63. 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, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 10 5 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 therein, or performs in that 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 that 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 in any case not exceed 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares or other rights, not being debt-claims, participating in profits, profits as well as other income from other rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 and the holding in respect of which the dividends are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 13, as the case may be, shall apply. 85. A resident of China who receives dividends paid by a company which is a resident of France may claim a refund of the prepayment (précompte) relating to those French dividends. Such refund may be taxed in France in accordance with the provisions of paragraph 2. 6. 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 StateotherState, 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 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, the tax so charged shall not exceed: (a) with respect to dividends paid by a company which is a resident of a Contracting State may also be taxed in that Contracting State according Thailand 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 Israel - 10 per cent of the gross amount of the dividends.; 3. Notwithstanding the provisions of paragraph 2, (b) with respect to 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 Israel to a resident of that other Contracting State and is eitherThailand: (ai) 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 10 per cent of the voting power gross amount of the dividends if the recipient holds at least 25 per cent of the capital of the company paying the dividends; or; (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) 15 per cent of subparagraph (l) the gross amount of paragraph 1 of Article 3. 4the dividends in all other cases. The provisions competent authorities of paragraphs 2 and 3 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. 5. 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. 63. 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, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 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 Dividends, paid by a company 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 that 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 10 15 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "dividends" as used in this Article means income from shares or from other rights, not being debt-claims, claims participating in profits, profits as well as the income from other rights corporate rights, which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 thereon, 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 establishmentestablishment or fixed base. In such case case, the provisions of Article 7 7, or Article 15, as the case may be, shall apply. 85. Where a company which is a resident of a Contracting State 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 not 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 that 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 Statedividends, the tax so charged shall not 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 therein, or performs in that 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 that 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 10 per cent 5 percent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares of any kind or other rights, not being debt-claims, participating in profits, as well as income from other rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, paragraph 1 and 2 and 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 who is the beneficial owner of the dividends 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 income or 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 that 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 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 15, as the case may be, shall apply. 85. 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 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 that 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 10 5 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 The competent authorities of the dividends is a resident Contracting States shall by mutual agreement settle the mode of that other Contracting State and is either: (a) a company which has owned directly or indirectly, for the period application of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power of the company paying the dividends; or (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of this limitation. This 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-debt claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14,as the case may be, shall apply. 85. 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 company′s undistributed profits to a tax on the company's 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 resident of a Contracting State having a permanent establishment in the other Contracting State, derives profits or income from that permanent establishment, any remittances of such profits or income by the permanent establishments to the company which is resident of the first mentioned Contracting State may, notwithstanding any other provisions of the Agreement, be taxed in accordance with the law of the other Contracting State, but the rate of tax imposed on such remittance shall not exceed 5 percent.

Dividends. 1. Dividends paid by a company which is a resident of a Contracting State territory to a resident of the other Contracting State territory may be taxed in that other Contracting Stateterritory. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in that Contracting State the territory of which the company paying the dividends is a resident and according to the laws of that Contracting Stateterritory, but if the beneficial owner of the dividends is a resident of the other Contracting Stateterritory, the tax so charged shall not exceed 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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 laws of the Contracting State territory of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 3 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting Stateterritory, carries on business 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 territory 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. Where a company which is a resident of a Contracting State territory derives profits or income from the other Contracting Stateterritory, that other Contracting State territory 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 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 Contracting Stateterritory, 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 Contracting Stateterritory.

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 that 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 or the dividends is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent 15 percent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. Where a company which is a resident of a Contracting State derives income or 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 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 or 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 StateotherState. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in that 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 dividend is a resident of the other Contracting State, the tax so charged shall not exceed 10 exceed: (a) 4 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 company (other Contracting State and is either: (athan a partnership) a company which has owned holds directly or indirectly, for the period of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power capital of the company paying the dividends; or; (b) a pension fund, provided that such 5 per cent of the gross amount of the dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of all other cases. This 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. 5. 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. 63. 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, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 ’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 provision 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 taxable under article 7, paragraph 1, may be subject to an additional tax in that other State, in accordance with its laws, but the additional charge shall not exceed 4 per cent of the amount of 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 Contracting State. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in that 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 10 ten 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 The competent authorities of the dividends is a resident Contracting States shall by mutual agreement settle the mode of that other Contracting State and is either: (a) a company which has owned directly or indirectly, for the period application of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power of the company paying the dividends; or (b) a pension fund, provided that such dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of this limitation. This 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 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 that 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 Statedividends, the tax so charged shall not exceed 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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 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 capital paying the dividends; (b) 10 per cent of the gross amount of the dividends. 3dividends in all other cases. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "“dividends" ” as used in this Article means means, income from shares or other rightsshares, not being debt-claims, participating participation in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishmentestablishment or fixed base. In such case case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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, 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 Contracting State. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in that 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 Statedividends, the tax so charged shall not exceed 10 per cent 10% of the gross amount of the such 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. The term "dividends" as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 3 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 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 a permanent establishmentestablishment or fixed base. In such case a case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 ’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 that 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 exceed: (a) 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 which has owned directly or indirectly, for the period of six months ending on the date on which entitlement to the dividends is determined, owns at least 10 per cent of the voting power stock of the company paying the dividends; or; (b) a pension fund, provided that such 15 per cent of the gross amount of the dividends are derived from the activities referred to in clause (ii) of subparagraph (l) of paragraph 1 of Article 3. 4all other cases. The provisions of paragraphs 2 and 3 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. 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 rights which is subjected to the same taxation treatment as income from shares by the taxation laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 Contracting State. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in that 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 10 per cent percent 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 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 10 per cent of the voting power of the company paying the dividends; 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 provision of paragraphs 2 and 3 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. 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 laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 Party to a resident of the other Contracting State Party may be taxed in that other Contracting StateParty. 2. However, such dividends paid by a company which is a resident of a Contracting State may also be taxed in that the Contracting State Party of which the company paying the dividends is a resident and according to the laws of that Contracting StateParty, but if the beneficial owner of the dividends is a resident of the other Contracting StateParty, the tax so charged shall not exceed 10 5 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State Party of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 3 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 therein, or performs in that 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 15, as the case may be, shall apply. 85. Where a company which is a resident of a Contracting State Party derives profits or income from the other Contracting StateParty, that other Contracting 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 Contracting 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 Contracting 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 Contracting StateParty. 6. The benefits of this Article shall not be available if 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 dividends are paid is 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 paid by a company which is a resident of a Contracting State may also be taxed in that 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, State the tax so charged shall not exceed 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "dividends" as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 that 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 10 per cent percent 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 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 10 per cent of the voting power of the company paying the dividends; 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 this paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 5. 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. 63. The term "“dividends" ” as used in this Article means income from shares shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 3 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 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 establishmentestablishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 85. 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 consists 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 that 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 10 per cent of the gross amount of the dividends. 3. Notwithstanding the provisions of This 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 10 per cent of the voting power of the company paying the dividends; 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. 5. 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. 63. The term "dividends" as used in this Article means income from all kinds of shares or other rights, not being debt-debt- claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 74. The provisions of paragraphs 1, 1 and 2 and 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 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 establishmentestablishment or fixed base. In such case the provisions of Article Articles 7 or 14, as the case may be, shall apply. 85. Where a company which is a resident of a Contracting State derives profits or oi 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 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.