1. Dividends paid by a company which is a resident of a Contracting State to a resident  of the other Contracting State may be taxed in that other State.  

2. However, such dividends may also be taxed in the Contracting State of which the  company paying the dividends is a resident and according to the laws of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so  charged shall not exceed:

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 25 per cent of  the capital of the company paying the dividends;  

b) 15 per cent of the gross amount of the dividends in all other cases.

The competent authorities of the Contracting States shall by mutual agreement settle the  mode of application of these limitations.  

This paragraph shall not affect the taxation of the company in respect of the profits out of  which the dividends are paid.

3. The term "dividends" as used in this Article means income from shares, "jouissance"  shares or "jouissance" rights, mining shares, founders' 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 laws of the State of  which the company making the distribution is a resident.  

4. 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 and the holding in respect of which the dividends  are paid is effectively connected with such permanent establishment. In such case the  provisions of Article 7 shall apply.  

5. 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 that 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 situated in that other State, nor  subject the company's undistributed profits to a tax on the company's undistributed profits,  even if the dividends paid or the undistributed profits consist wholly or partly of profits or  income arising in such other State.