Surinam - 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 be taxed in the State of which the company paying the dividends is a
resident, and according to the law of that State, but the tax so charged shall not exceed:

(a) 7.5 per cent of the gross amount of the dividends, if the recipient is a company whose capital is
divided, wholly or partly, into shares and which owns directly at least 25 per cent of the capital of the
company paying the dividends, provided that the relationship between the two companies is not
established or being maintained for the primary purpose of enjoying the benefit of the lower rate;

(b) 15 per cent of the gross amount of the dividends not specified in subparagraph (a), if the
dividends are not included in the basis for levying the tax in the country of which the recipient is a
resident;

(c) 20 per cent of the gross amount of the dividends in all other cases.

3. 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.

4. The term “dividends” as used in this article means income from shares, jouissance shares or
jouissance rights, founders' shares or other rights participating in profits as well as income from bonds
and debentures or debt-claims participating in profits and income from other corporate rights
assimilated to income from shares by the taxation law of the State of which the company making the
distribution is a resident.

5. The provisions of paragraphs 1 and 2 shall not apply if the recipient of the dividends, being a
resident of one of the States, has in the other State, of which the company paying the dividends is a
resident, a permanent establishment with which the holding by virtue of which the dividends are paid
is effectively connected. In such a case, the provisions of article 7 shall apply.

6. 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 dividends paid by the company to persons who are
not residents of that other State, or subject the company's undistributed profits to a tax on
undistributed profits, even if the dividends paid on the undistributed profits consist wholly or partly of
profits or income arising in such other State.

Protocol:

VI. Ad article 10.

The provisions of article 10, paragraph 2, shall not apply in respect of dividends paid by
a company which is a resident of Surinam to a company which is a resident of the Netherlands, if the
latter company is subject in the Netherlands to corporate tax on the dividends received. In such cases
the provision in article 10, paragraph 2, subparagraph (c), shall apply.

VII. Ad articles 10, 11 and 12.

Applications for the refund of taxes collected contrary to the provisions of
articles 10, 11 and 12 must be submitted to the competent authority of the State which collected the
tax within a period of five years after the end of the calendar year in which the tax was collected.