Article 10 Dividends
     1. Dividends paid by a company which is a resident of one of the States to a resident of the other State may be taxed in that other State.
     2. However, such dividends may be taxed in the 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 not exceed:
(a) 5 per cent of the gross amount of the dividends if the recipient is a joint-stock or limited company which holds directly at least 25 per cent of the capital of the company paying the dividends:
(b) in all other cases, 15 per cent of the gross amount of the dividends.
3. (a) Dividends paid by a company being a resident of France which would entitle the recipient to a tax credit (avoir fiscal) if he were a resident of France shall when paid to residents of the Netherlands entitle the recipient to a gross payment from the French Treasury in an amount equal to such tax credit, subject to deduction of the tax referred to in paragraph 2 (b) above.
(b) The provisions of subparagraph (a) shall apply to the following recipients who are residents of the Netherlands:
(i) Individuals who are subject to Netherlands tax in respect of the aggregate of the dividends distributed by the company being a resident of France and the gross amount of the payment referred to in subparagraph (a) in connexion with such dividends;
(ii) Companies which are subject to Netherlands tax in respect of the aggregate of the dividends distributed by the company being a resident of France and the gross amount of the payment referred to in subparagraph (a) in connexion with such dividends;
(iii) Investment companies or investment funds which are not covered by the provisions of (ii) above and which meet the conditions determined by the competent authorities by mutual agreement.
     4. An individual being a resident of the Netherlands who receives dividends distributed by a company being a resident of France may, unless he is eligible for the payment referred to in paragraph 3, apply for a refund of any prelevy (precompte) paid in respect of such dividends by the company making the distribution, subject to deduction of the tax referred to in paragraph 2 above.
5. (a) 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 assimilated to income from shares by the taxation law of the State of which the company making the distribution is a resident.
(b) Dividends paid by a company being a resident of France shall also be deemed to include the gross payment representing the tax credit referred to in paragraph 3 and the gross reimbursements in respect of the prelevy which are referred to in paragraph 4 and which are made in connexion with dividends paid by such company.
     6. The provisions of paragraphs 1 to 4 shall not apply if the recipient of the dividends, being a resident of one of the States, has in the other State, of which the company paying the dividends is a resident, a permanent establishment with which the holding by virtue of which the dividends are paid is effectively connected. In such a case, the provisions of article 7 shall apply.
     7. Where a company which is a resident of one of the States derives profits or income from the other State, that other State may not impose any tax on the dividends paid by the company to persons who are not residents of that other State, or subject the company's undistributed profits to a tax on undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.