<h3>Tax Rates</h3><table><thead><tr><th>Item</th><th>Article reference</th><th>Applicable Rates</th><th>Comments</th></tr></thead><tbody><tr><td>Dividends</td><td>Article 10</td><td>5%<br>10%<br>0%</td><td>5% if beneficial owner is a company the capital of which is wholly or partly divided into shares which holds directly at least 10% of the capital of the company paying the dividends; 10% in all other cases. 0% if beneficial owner is the State itself, a political subdivision, local government, or the Central Bank thereof, a pension fund, the Abu Dhabi Investment Authority, Abu Dhabi Investment Council or any other institution created by the Government. Anti-abuse rule in Article 10(8). Income from partial liquidation or purchase of own shares treated as income from shares (Protocol Ad Articles 10 & 13). Netherlands can apply national legislation for preserving tax assessment on substantial interest (Protocol Ad Articles 10 & 13).</td></tr><tr><td>Interest</td><td>Article 11</td><td>0% (residence state only)</td><td>Taxable only in the residence state of the beneficial owner. Anti-abuse rule for special relationships (Article 11(4)).</td></tr></tbody></table>