ARTICLE 11A

Branch Tax

Notwithstanding any other provisions of this Convention, a company that is a resident of a Contracting State may be subject in the other Contracting State to a tax in addition to the tax on profits. Such additional tax, however, may not exceed:

a) 5 percent of the “dividend equivalent amount” of the business profits of the company that are either attributable to a permanent establishment in that other State or are subject to tax on a net basis in that other State under Article 6 (Income From Immovable Property (Real Property)) or paragraph 1 of Article 13 (Gains); and

b) 10 percent of the “excess interest.” In the case of persons referred to in subparagraph a) of paragraph 2 of Article 11 (Interest), the tax imposed under this subparagraph shall not be levied at a rate in excess of 4.95 percent.