<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>15%<br>0% (residence state only)</td><td>5% if the beneficial owner is a company (other than a partnership) which holds directly more than 50% or at least 10 million USD of the capital of the company paying the dividends.<br>15% in all other cases.<br>Taxable only in the other Contracting State if the beneficial owner is the Government of that other Contracting State or any of its institutions, or other entity the capital of which is wholly-owned by the Government of that other Contracting State.</td></tr><tr><td>Interest</td><td>Article 11</td><td>10%<br>0% (residence state only)</td><td>10% of the gross amount of the interest.<br>Exempt if paid between the Governments, Central Banks, certain investment/development funds, or other wholly government-owned entities of the Contracting States.</td></tr></tbody></table>