<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 holding directly or indirectly, for 6 months, at least 10% of the voting shares of the company paying the dividends. (Does not apply to dividends from certain Japanese companies that can deduct dividends paid to beneficiaries in computing taxable income). : 10%: in all other cases.</td></tr><tr><td>Interest</td><td>Article 11</td><td>0% : 10%</td><td>0% (residence state only): if beneficially owned by the Government, a political subdivision or local authority, central bank, or any institution wholly owned by that Government. Also, if beneficially owned by a resident with respect to debt-claims guaranteed, insured or indirectly financed by such entities. (For interest arising in Kuwait and beneficially owned by a Japanese pension fund, it shall be taxable only in Japan). : 10%: in all other cases.</td></tr></tbody></table>