<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>0% (residence state only)</td><td>If beneficial owner carries on business through a permanent establishment or performs independent personal services from a fixed base in the source state, and the holding is effectively connected, then Article 7 or Article 14 applies.</td></tr><tr><td>Interest</td><td>Article 11</td><td>0% (residence state only)</td><td>If beneficial owner carries on business through a permanent establishment or performs independent personal services from a fixed base in the source state, and the debt-claim is effectively connected, then Article 7 or Article 14 applies, and the tax so charged shall not be more than 5% of the gross amount of such interest.</td></tr></tbody></table>