<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>Taxable only in the residence state of the beneficial owner. This does not affect the taxation of the company in respect of the profits out of which the dividends are paid. Not applicable if the holding is effectively connected with a permanent establishment or fixed base in the source state.</td></tr><tr><td>Interest</td><td>Article 11</td><td>0% (residence state only)</td><td>Taxable only in the residence state of the beneficial owner. Not applicable if the debt-claim is effectively connected with a permanent establishment or fixed base in the source state.</td></tr></tbody></table>