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 if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed 15 percent of the gross amount of the dividends.
     3. Notwithstanding the provisions of paragraph 2 the State of which the company paying the dividends is a resident shall not levy a tax on dividends, if the dividends are beneficially owned by a company (other than a partnership) which is a resident of the other State and holds directly at least 25 percent of the capital of the company paying the dividends.
     4. Notwithstanding paragraph 3, if and as long as in one of the States the rate of tax imposed on distributed company profits is lower than the rate of tax imposed on undistributed company profits and the difference between both rates amounts to 10 percentage points or more, each of the States may levy a tax on dividends, paid by a company which is a resident of one of the States to a company (other than a partnership) which is a resident of the other State and holds directly at least 25 percent of the capital of the company paying the dividends, but the tax so charged shall not exceed:
a. 5 per cent of their gross amount, if the above-mentioned difference amounts to 15 percentage points or less;
b. 10 per cent of their gross amount, if the above-mentioned difference amounts to more than 15 percentage points.
     Where, however, in one of the States the above-mentioned difference amounts to more than 20 percentage points, that State may levy a tax on the dividends, which may not exceed 15 per cent of their gross amount.
     5. The provisions of paragraphs 2, 3 and 4 shall not affect the taxation of the company in respect of the profits out of which the dividends are paid.
     6. The term 'dividends' as used in this Article means income from shares, 'jouissance' shares or 'jouissance' rights, mining shares, founders' shares or other rights 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. In the case of the Netherlands the term includes also income from profit sharing bonds.
     7. The provisions of paragraphs 1, 2, 3 and 4 shall not apply if the beneficial owner of the dividends, being a resident of one of the States, carries on business in the other State of which the company paying the dividends is a resident, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply.
     8. 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, except insofar as such dividends are paid to a resident of that other State or insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment or a fixed base situated in 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.