<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>10(2), 10(3)</td><td>5%, 15%, or 0% (residence state only)</td><td>5%: beneficial owner is a company (excluding groups of persons) holding directly at least 20% of the capital of the paying company for a 365-day period. 15%: other cases. 0% (residence state only): beneficial owner is the State, political subdivision, local government, Central Bank, pension fund, or qualified government entity.</td></tr><tr><td>Interest</td><td>11(2), 11(3)</td><td>5%, 10%, or 0% (residence state only)</td><td>5%: maturity of the loan is at least five years. 10%: maturity of the loan is less than five years. 0% (residence state only): beneficial owner is the State, political subdivision, local government, Central Bank, pension fund, or qualified government entity.</td></tr></table>