<h3>Tax Rates</h3><table><thead><tr><th>Item</th><th>Article reference</th><th>Applicable Rates</th><th>Comments</th></tr></thead><tbody><tr><td>Dividends</td><td>Article 10</td><td>0% (residence state only)</td><td>Taxable only in the residence state of the beneficial owner. Does not apply if the beneficial owner has a PE or fixed base in the source state to which the holding is effectively connected (then Article 7 or 14 applies).</td></tr><tr><td>Interest</td><td>Article 11</td><td>0% (residence state only)</td><td>Taxable only in the residence state of the beneficial owner. Does not apply if the beneficial owner has a PE or fixed base in the source state to which the debt-claim is effectively connected (then Article 7 or 14 applies).</td></tr></tbody></table>