Dividends

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.... 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)___per cent [the percentage is to be established through bilateral negotiations] of the gross amount of the dividends if the beneficial owner is a company which holds directly at least 25 per cent of the capital of the company paying the dividends throughout ....

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....ares, "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 which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident. 4. The provisions of paragraphs 1 and 2 shall no....