"Article 10 DIVIDENDS

1. Dividends paid by a company which is a resident of a Contracting State or distributions paid by a real estate investment fund established under the laws of a Contracting State to a resident of the other Contracting State may be taxed In that other State.

2. However, dividends paid by a company which is a resident of a Contracting State or distributions paid by a real estate investment fund established under the laws of a Contracting State may also be taxed in that State according to the laws of that State, but if the beneficial owner of the dividends or distributions is a resident of the other Contracting State, the tax so charged shall not exceed:

3. Notwithstanding the provisions of paragraph 2, dividends or distributions arising in a Contracting State and paid to the Government of the other Contracting State shall be exempt from tax in the first-mentioned Contracting State.

4. For the purpose of paragraph 3, the term Government includes:

5. The term "dividends" as used in this Article means income from shares, or other rights, not being debt claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the taxation laws of the Contracting State of which the company making the distribution is a resident. The term "shares" as used in this Article shall include depository receipts thereof. For the purposes of paragraphs 7, 8 and 9 of this Article, the tem "dividends" also includes distributions within the meaning of subparagraph b) of paragraph 2 of this Article and reference to a company shall be read as including reference to a real estate investment fund as appropriate.

6. The term "real estate investment fund" as used in this Article means:

7. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14 of this Agreement, as the case may be, shall apply.

8. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not impose any tax on the dividends paid by the company, except insofar as such dividends are paid to a resident of that other State or insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment or a fixed base situated in that other State, nor subject the company's undistributed profits to a tax on undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in that other State.

9. The provisions of this Article shall not apply if it was the main purpose of any person concerned with the creation or assignment of the shares, units or other rights in respect of which the dividend is paid to take advantage of this Article by means of that creation or assignment."