- 1.Notwithstanding paragraph 2 of Article 10, the Contracting State of which the company is a resident shall not levy a tax on dividends paid by that company, if the beneficial owner of the dividends is a pension fund referred to in paragraph 2 of Article 4.
- 2.It is understood that, for the purposes of this Convention,
- a)the term “jouissance shares” means securities that grant the right to participate in the net profit of the company and do not represent capital of the company but represent a non financial contribution, such as a contribution in know how;
- b)the term “jouissance rights” means rights, whether or not documented by official papers, to participate in the net profit of the company, that do not represent capital of the company but represent a non financial contribution, such as a contribution in know how;
- c)the term “mining shares” means shares in a mining company subject to mining law and organised in a specific legal form;
- d)the term “founders’ shares” means shares that are issued as remuneration for services rendered by founders during the constitution of a company and do not represent capital of the company.
