<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%</td><td>If the beneficial owner of the dividends is a resident of the other Contracting State.</td></tr><tr><td>Dividends</td><td>Article 10</td><td>0% (source state only)</td><td>If the beneficial owner is the Government of the other Contracting State or any governmental institution/entity thereof as defined in Article 4(2); or a company which is a resident of the other Contracting State and is controlled or at least 25% of its capital is owned directly or indirectly by such Government/institution/entity.</td></tr></tbody></table>