Greece - Dividend

Article 10. Dividends

1. Dividends paid by a company which is a resident of one of the States to a resident of the other State may be taxed in that other
State.

2. However, such dividends may also be taxed in the State of which the company paying the dividends is a resident and according to
the laws of that State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed:

a with respect to dividends paid by a company which is a resident of the Netherlands to a resident of Greece:

i. 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly
at least 25 per cent of the capita( of the company paying the dividends;

ii. 15 per cent of the gross amount of the dividends in all other cases;

b with respect to dividends paid by a company which is a resident of Greece to a resident of the Netherlands: 35 per cent of the
gross amount of the dividends.

The competent authorities of the States shall by mutual agreement settle the mode of application of these limitations. 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 participating in profits, as well as income from debt-claims participating in profits, and 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 not apply if the beneficial owner of the dividends, being a resident of one of the States,
carries on business in the other State of which the company paying the dividends is a resident, through a permanent establishment
situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the holding in
respect of which the dividends are paid is effectively connected with such permanent establishment or fixed base. In such case the
provisions of Article 7 or Article 15, as the case may be, shall apply.

5. Where a company which is a resident of one of the States derives profits or income from the other State, that other State may not
impose any tax on the dividends paid by the company, except insofar as such dividends are paid to a resident of that other State or
insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment or a fixed
base situated in that other State, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even
if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.

Protocol:

I. Ad Article 10

It is agreed that since the difference between the provisions of sub-paragraph a) and those of sub-paragraph b) of paragraph 2 of
Article 10 is based on the fact that according to the Greek income tax on legal entities as in force at the date of signature of the
Convention dividends paid by a company which is a resident of Greece are deductible in the computation of the profits of the
company paying the dividends, the two Governments will undertake the review of the said provisions in order to adapt sub-paragraph
b) to sub-paragraph a) when the basis of such difference no longer exists.

II. Ad Articles 10, 11 and 12

Applications for the restitution of tax levied contrary to the provisions of Articles 10, 11 and 12 have to be lodged with the competent
authority of the State having levied the tax within a period of three years after the expiration of the calendar year in which the tax has
been levied.