India - 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 15 per cent of
the gross amount of the dividends.

3. The competent authorities of the States shall by mutual agreement settle the mode of application of paragraph 2.

4. The provisions of paragraph 2 shall not affect the taxation of the company in respect of the profits out of which the dividends are
paid.

5. 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.

6. 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 of fixed base. In such case the
provisions of Article 7 or Article 14, as the case may be, shall apply.

7. 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 of 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:

IV. Ad Articles 10, 11 and 12

1. Where tax has been levied at source in excess of the amount of tax chargeable under the provisions of Articles 10, 11 or 12,
applications for the refund of the excess amount of tax 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.

2. If after the signature of this Convention under any Convention or Agreement between India and a third State which is a member
of the OECD India should limit its taxation at source on dividends, interest, royalties, fees for technical services or payments for the
use of equipment to a rate lower or a scope more restricted than the rate or scope provided for in this Convention on the said items
of income, then, as from the date on which the relevant India Convention or Agreement enters into force the same rate or scope as
provided for in that Convention or Agreement on the said items of income shall also apply under this Convention.