Article 10 (Dividends):
Paragraph 2. Dividends may 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) 5 % of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 % of the capital of the company paying the dividends;
(b) 15 % of the gross amount of the dividends in all other cases.
Article 11 (Interest):
Paragraph 2. Interest may be taxed in the Contracting State in which it arises and according to the laws of that State, but if the recipient is the beneficial owner of the interest the tax so charged shall not exceed 10 % of the gross amount of the interest.
Paragraph 8. Notwithstanding the provisions of paragraph 2 of this Article, interest arising in a Contracting State shall be exempt from tax in that State if it is received and beneficially owned by the Government of the other Contracting State or its political subdivision, or a statutory body thereof or the National Bank of that other State.
Paragraph 9. Notwithstanding the provisions of Article 7 of this Convention and paragraph 2 of this Article, interest arising in a Contracting State paid to and beneficially owned by a resident of the other Contracting State shall be exempt from tax in the first-mentioned State if it was paid in respect of loan made, guaranteed or insured or in respect of any other debt-claim or loan guaranteed or insured on behalf of the other Contracting State by its authorised organ.
Article 12 (Royalties):
Paragraph 2. Royalties may be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 10 % of the gross amount of the payments.
