Article 10 Dividends
     1. Dividends paid by a person which is a resident of a State to a resident of the other State may be taxed in that other State.
     2. However, such dividends may also be taxed in the State of which the person paying the dividends is a resident and according to the laws of that State, but the tax so charged shall not exceed 15 per cent of the gross amount of the dividends.
     3. The competent authority of the State of which the person paying the dividends is a resident, shall settle the mode of application of paragraph 2.
     4. The provisions of paragraph 2 shall not affect the taxation of the person paying the dividends in respect of the profits out of which the dividends are paid.
     5. The term 'dividends' as used in this Article means income from shares and income from rights which is subjected to the same taxation treatment as income from shares by the laws of the State of which the person distributing the profits is a resident.
     6. The provisions of paragraphs 1 and 2 shall not apply if the recipient of the dividends, being a resident of a State, carries on business or performs activities other than employment in the other State of which the person 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 5 shall apply.