<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%; 10%</td><td>5% if beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends or if the beneficial owner is: in the case of the State of Qatar, the Government of the State of Qatar, a political or administrative subdivision, a local authority or a statutory body thereof, the Qatar Central Bank or any institution wholly owned, directly or indirectly, by the Government of the State of Qatar, its political or administrative subdivisions, local authorities or statutory bodies (including Qatar Investment Authority and its affiliates as per Protocol); and in the case of the Portuguese Republic, the State, a political or administrative subdivision or a local authority thereof, or the Central Bank of Portugal. 10% in all other cases.</td></tr><tr><td>Interest</td><td>Article 11</td><td>0%; 10%</td><td>0% if beneficial owner is the Government of Qatar/Portugal, a political/administrative subdivision, local authority or statutory body thereof, or the Central Bank of Portugal (including Qatar Central Bank or any institution wholly owned, directly or indirectly, by the Government of the State of Qatar, its political or administrative subdivisions, local authorities or statutory bodies, or Qatar Investment Authority and its affiliates as per Protocol). 10% in all other cases.</td></tr></tbody></table>