<h3>Tax Rates</h3><table><tr><th>Item</th><th>Article reference</th><th>Applicable Rates</th><th>Comments</th></tr><tr><td>Dividends</td><td>Article 10</td><td>0% (residence state only)</td><td>Taxable only in the recipient's residence state. Not applicable where the holding is effectively connected with a PE in the source state: Article 7 then applies.</td></tr><tr><td>Interest</td><td>Article 11</td><td>0% (residence state only)</td><td>Termed income from debt claims (includes Islamic financial instruments assimilable to a loan); taxable only in the recipient's residence state. PE carve-out redirects to Article 7; non-arm's length excess taxed under domestic law.</td></tr></table>