<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 in the recipient's state of residence; the Article gives the source state no taxing right and sets no rate. Not applicable where the holding is effectively connected with a PE or fixed base in the source state (then Article 7 or 14).</td></tr><tr><td>Interest</td><td>Article 11</td><td>10% of gross amount</td><td>Source state may also tax, capped at 10% of the gross amount for a beneficial owner. Interest beneficially owned by the other State, its subdivisions, agencies or Central Bank is exempt at source. Carve-out to Article 7 or 14.</td></tr></table>