<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% / 5%</td><td>0% if beneficial owner is the Government of the other Contracting State, its administrative subdivisions/local authorities, its Central Bank, a financial institution wholly owned by its Government, or a company (other than a partnership) resident in the other State holding directly at least 25% of the capital of the company paying the dividends. / 5% in all other cases (may also be taxed in residence state).</td></tr><tr><td>Interest</td><td>Article 11</td><td>0% / 5%</td><td>0% if beneficially owned by the Government of the other Contracting State, its administrative subdivisions/local authorities, its Central Bank, a financial institution wholly owned by its Government, a company (other than a partnership) resident in the other State, or any resident person of the other State for loans guaranteed by the Government of either State. / 5% in all other cases (may also be taxed in residence state).</td></tr></tbody></table>