Article 13 - Dividends
     (1) Dividends received by a person domiciled in one of the Contracting States from the other State shall be subject to taxation by the State of domicile.
     (2) To the extent that in the other Contracting State the tax on income from capital is collected by deduction (at the source), the right to make such tax deductions shall not be affected.
     (3) Tax deducted as provided in paragraph (2) shall not exceed 15 per cent of the dividends.
     (4) Tax deducted as provided in paragraph (2) shall not, however, exceed 10 per cent of the dividends if these are paid by a joint-stock company domiciled in one of the Contracting States to a joint-stock company domiciled in the other State and holding at least 25 per cent of the voting shares of the first-mentioned company.
     (5) The provisions of paragraphs (1) to (4) shall not apply where a person domiciled in one of the Contracting States has a permanent establishment in the other State and realizes the income through that establishment. In this case the income shall be subject to taxation by the latter State.