<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 11</td><td>0% (residence state only)</td><td>Taxable only in residence state. Does not apply if the holding is effectively connected with a permanent establishment or fixed base.</td></tr><tr><td>Interest</td><td>Article 12</td><td>0% (residence state only)</td><td>Taxable only in residence state. Does not apply if the debt-claim is effectively connected with a permanent establishment or fixed base. Non-arm's length excess remains taxable according to domestic laws.</td></tr></table>