<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 12</td><td>10%</td><td>Source state capped at 10% for a beneficial owner. Dividends paid to the other Government or its wholly owned institutions are exempt at source. Not applicable where the holding is connected with a PE or fixed base (then Article 9).</td></tr><tr><td>Interest</td><td>Article 13</td><td>0% (residence state only)</td><td>Taxable only in the residence state of the beneficial owner. Not applicable where the debt-claim is connected with a PE or fixed base in the source state (then Article 9).</td></tr></table>