Notwithstanding paragraph 6 of Article 10, it is understood that the term “dividends” also means income from debt-claims provided that the law of a Contracting State subjects this income from debt-claims to the same taxation treatment as income from shares according to a combination of the following criteria:
- – the redemption date of a loan;
- – the size of the remuneration or indebtedness of the remuneration is depending on the profit or the distributions of profits; and
- – the subordination of a loan.