Article 10 Dividends
     1. Dividends paid by a company which is a resident of a territory to a resident of the other territory may be taxed in that other territory.
     2. However, such dividends may also be taxed in the territory of which the company paying the dividends is a resident and according to the laws of that territory, but if the beneficial owner of dividends is a resident of the other territory, the tax so charged shall not exceed 10 percent of the gross amount of the dividends.
     3. The competent authorities of the territories shall by mutual agreement settle the mode of application of paragraph 2.
     4. The provisions of paragraph 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, 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 taxation laws of the territory 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 a territory, carries on business in the other territory of which the company paying the dividends is a resident, through a permanent establishment situated therein, or performs in that other territory 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.
     7. Where a company which is a resident of a territory derives profits or income from the other territory, no tax may be imposed in that other territory on the dividends paid by the company, except insofar as such dividends are paid to a resident of that other territory 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 territory, 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 territory.