Notwithstanding the provisions of sub-paragraph a) of paragraph 2 of Article 10, as long as, under the provisions of the Netherlands Company Tax Act and to the future amendments thereto, a company which is a resident of the Netherlands is not charged to Netherlands company tax with respect to dividends the company receives from a company which is a resident of Turkey, the percentage provided for in that sub-paragraph shall be lowered to:
- a)10 per cent with respect to dividends paid by a company which is a resident of Turkey; and
- b)5 per cent with respect to dividends paid by a company which is a resident of the Netherlands. In such case the provisions of sub-paragraph d) of paragraph 2 of Article 23 shall be applied accordingly.