<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>0% (residence state only)</td><td>If the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment or performs independent personal services from a fixed base, and the holding is effectively connected with such PE or fixed base, then Article 7 or Article 13 applies.</td></tr><tr><td>Interest</td><td>Article 11</td><td>0% (residence state only)</td><td>If the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment or performs independent personal services from a fixed base, and the debt-claim is effectively connected with such PE or fixed base, then Article 7 or Article 13 applies.</td></tr></tbody></table>