The 2010 treaty and protocol to replace the current treaty dating from 1981 entered into force on 18 May 2011 and will generally apply as from 1 January 2012. When in effect, dividends will be exempt if paid (1) to a company (other than a partnership) that holds directly at least 10% of the capital of the paying company for an uninterrupted period of at least one year, or (2) to a pension fund or other similar institution providing pension schemes provided the pension fund or similar institution is established, recognized for tax purposes and controlled in accordance with the laws of that other state. Otherwise, the rate will be 15%. Interest and royalties will be exempt from tax.

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