Article 2

"a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 10 per cent of the capital of the company paying the dividends;"

"3. The term "dividends" as used in this Article means income from shares of any kind and 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 laws of the State of which the company making the distribution is a resident. This term also means any payments on units of the mutual investment funds or similar collective investment vehicles (other than collective investment vehicles organized primarily for investing in immovable property, if at least 10 per cent of the units or other rights of such a vehicle belongs to the beneficial owner of that income)."