<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% / 15%</td><td>5%: if beneficial owner is a company (other than a partnership) which has owned directly or indirectly at least 25% of the capital of the company paying the dividends for a period of at least 12 months preceding the date the dividends were declared; 15%: in all other cases.</td></tr><tr><td>Interest</td><td>Article 11</td><td>0% / 5%</td><td>0%: if the payer of the interest is the Government of that Contracting State or a local authority thereof; or the interest is paid to the Government of the other Contracting State or local authority thereof or any agency or instrumentality (including a financial institution) wholly owned by that other Contracting State or local authority thereof; or the interest is paid to any other agency or instrumentality (including a financial institution) in relation to loans made in application of an agreement concluded between the Governments of the Contracting States. 5%: in all other cases if the recipient is the beneficial owner of the interest.</td></tr></tbody></table>