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 also be taxed in the State of which the company paying the dividends is a resident and according to the laws of that State, but the tax so charged shall not exceed:
(a) 10 per cent of the gross amount of the dividends where the beneficial owner is a company, all or part of the capital of which is in the form of shares and which directly owns at least 25 per cent of the capital of the company paying the dividends, provided that the relationship between the two companies was not established and is not being maintained primarily for the purpose of enabling them to benefit from this reduced rate;
(b) 25 percent of the gross amount of the dividends, in all other cases.
     3. The competent authorities of the States shall by mutual agreement settle the mode of application of paragraph 2.
     4. The provisions of paragraphs 1 and 2 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, 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 State of which the company making the distribution is a resident.
     6. The provisions of paragraphs 1 and 2 shall not apply, if the beneficial owner 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 in respect of which the dividends are paid is effectively connected. In such 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, 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.