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ARTICLE 8

Shipping and Air Transport

1.Profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in

international traffic shall be taxable only in that Contracting State.

2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint

business or an international operating agency, including a consortium or a similar form of association.

ARTICLE 9

Associated Enterprises

1. Where

(a) an enterprise of a Contracting State participates directly or indirectly in the management, control or

capital of an enterprise of the other Contracting State, or

(b) the same persons participate directly or indirectly in the management, control or capital of an

enterprise of a Contracting State and an enterprise of the other Contracting State,

and in either case conditions are made or imposed between the two enterprises in their commercial or

financial relations which differ from those which would be made between independent enterprises, then any

profits which would, but for those conditions, have accrued to one of the enterprises, but, by the reason of

those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

2. Where a Contracting State includes in the profits of an enterprise of that State – and taxes accordingly

– profits on which an enterprise of the other Contracting State has been charged to tax in that other State and

the profits so included are profits which would have accrued to the enterprise of the first-mentioned State if the

conditions made between the two enterprises had been those which would have been made between

independent enterprises, then that other State, if it agrees that the adjustment made by the first-mentioned

State is justified both in principle and as regards the amount, shall make an appropriate adjustment to the

amount of the tax charged therein on those profits. In determining such adjustment, due regard shall be had to

the other provisions of this Agreement and the competent authorities of the Contracting States shall if

necessary consult each other.

ARTICLE 10

Dividends

1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other

Contracting State may be taxed in that other Contracting State.

2. However such dividends may also be taxed in the Contracting State of which the company paying the

dividends is a resident and according to the laws of that State, but if the beneficial owner of the dividends is a

resident of the other Contracting State, the tax so charged shall not exceed:

(a) 5 per cent of the gross amount of the dividends if the recipient is a company (excluding partnerships)

which owns directly at least 70 per cent of the capital of the company paying the dividends;

(b) 10 per cent of the gross amount of the dividends if the recipient is a company (excluding partnerships)

which owns directly at least 25 per cent of the capital of the company paying the dividends;

(c) 15 per cent of the gross amount of the dividends in all other cases.

This paragraph shall not affect the taxation of the company in respect of the profits out of which the

dividends are paid.

3. The term “dividends” as used in this Article means income from shares, “jouissance” shares or

“jouissance” rights, mining shares, founders' shares or other rights, not being debt-claims, participating in

profits, as well as income from other corporate rights or other income which is subjected to the same taxation