Article 9   Dividends - interest - royalties
     (1) Subject to the provisions of paragraph (2) of this article, the right of either of the two States to tax by deduction at source income from movable capital shall not be restricted by the fact that such income is subject to direct taxation only in the State designated in paragraph (1) of article 2.
     (2) In the case of tax on income from movable capital levied by one of the two States by deduction at source, the recipient of such income domiciled in the other State may, within a period of two years, request reimbursement through the State in which he is domiciled, subject to the production of an official certificate of domicile and of liability to direct taxation in the State of domicile:
a. In respect of dividends:
(i) Of the total amount of the tax, where the recipient of the dividends is a joint-stock company which owns at least 25 per cent of the authorized capital of the company paying the dividends, provided that the relationship between the two companies was not established, or is not maintained, primarily in order to obtain the benefit of such total reimbursement;
(ii) Of the amount of the tax which exceeds 15 per cent of the dividends, in all other cases.
b. In respect of other income from movable capital: of the amount of the tax which exceeds 5 per cent of the capital yield.
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