<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>10%</td><td>5%: if the beneficial owner is a company that has owned directly or indirectly, for the period of six months ending on the date on which entitlement to the dividends is determined, at least 10 per cent of the voting power or of the total issued shares of the company paying the dividends. This rate shall not apply to dividends paid by a company which is entitled to a deduction for dividends paid to its beneficiaries in computing its taxable income in Japan.<br>10%: in all other cases.</td></tr><tr><td>Interest</td><td>Article 11</td><td>0% (residence state only)<br>10%</td><td>0% (residence state only): if the interest is beneficially owned by the Government of that other Contracting State, a political subdivision or local authority thereof, the central bank thereof or any institution wholly owned by the Government thereof; or if the interest is beneficially owned by a resident of that other Contracting State with respect to debt-claims guaranteed, insured or indirectly financed by the Government of that other Contracting State, a political subdivision or local authority thereof, the central bank thereof or any institution wholly owned by the Government thereof; or if the beneficial owner is a bank, an insurance company, a securities dealer, or any other enterprise fulfilling specific financial asset/liability conditions; or if the beneficial owner is a pension fund meeting specific beneficiary/member residency criteria.<br>10%: in all other cases.</td></tr></tbody></table>