<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 11</td><td>0% (residence state only)</td><td>Taxable only in the residence state of the beneficial owner. This provision shall not apply if the main purpose of creation or assignment of shares was to take advantage of this Article. If the beneficial owner has a permanent establishment or fixed base in the source state and the holding is effectively connected, then business profits or independent personal services rules apply. Government entities and their financial institutions are taxable only in the state of residence.</td></tr><tr><td>Interest</td><td>Article 12</td><td>0% (residence state only)</td><td>Taxable only in the residence state of the beneficial owner. This provision shall not apply if the main purpose of creation or assignment of the debt-claim was to take advantage of this Article. If the beneficial owner has a permanent establishment or fixed base in the source state and the debt-claim is effectively connected, then business profits or independent personal services rules apply. Government entities and their financial institutions are taxable only in the state of residence.</td></tr></tbody></table>