Article 11 - Dividends
     1. Dividends paid by a company which is a resident of a country to a resident of the other country may be taxed in that other country.
     2. However, such dividends may be taxed in the country of which the company paying the dividends is a resident, and according to the laws of that country, but the tax so charged shall not exceed 15 per cent of the gross amount of the dividends.
     3. Notwithstanding the provisions of paragraph 2, the tax so charged shall not exceed 5 per cent of the gross amount of the dividends, if the recipient of the dividends is a company which owns at least 25 per cent of the voting shares of the company paying the dividends during the period of six months immediately before the end of the accounting period for which the distribution of profits takes place.
     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 term "dividends" as used in this Article means income from shares, "jouissance" shares or "jouissance" rights, founders' shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights assimilated to income from shares by the taxation laws of the country of which the company making the distribution is a resident.
     6. The provisions of paragraphs 1, 2 and 3 shall not apply if the recipient of the dividends, being a resident of a country, has in the other country, 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 8 shall apply.
     7. Where a company which is a resident of a country derives profits or income from the other country, that other country may not impose any tax on the dividends paid by the company to persons who are not residents of that other country, 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 that other country.