Article 10 Dividends
     1. Dividends paid by a company that is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State.
     2. However, such dividends may also be taxed in the contracting 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:
a) 0 percent of the gross amount of the dividends if the beneficial owner is a company that holds directly at least 10 percent of the capital of the company paying the dividends;
b) 20 percent of the gross amount of the dividends in all other cases.
     The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of these limitations.
     This paragraph shall not affect the taxation of the company in respect to the profits out of which the dividends are paid.
     3. The provisions of paragraphs 1 and 2, subsection a, shall apply on the condition that the relationship between the company paying the dividend and the beneficial recipient of the dividend is not primarily established or maintained in order to benefit from the lower percentage as stipulated in paragraph 2, subsection a.
     4. 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 in which the company making the distribution is a resident.
     5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of a contracting State, carries out business in the other Contracting State in 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.
     6. Where a company that is a resident of a Contracting State derives profits or income from the other Contracting 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.