Article 10

DIVIDENDS (AUSTRALIA)
1. Dividends paid by a company which is a resident of one of the Contracting States under the law of that State
relating to its tax, being dividends to which a resident of the other Contracting State is beneficially entitled,
may be taxed in that other State.
2. Those dividends may be taxed in the first-mentioned Contracting State and according to the law of that
State, but the tax so charged shall not exceed 15% of the gross amount of the dividends. The competent
authorities of the Contracting States shall by mutual agreement settle the mode of application of this
limitation.

Capital gain :
Income, profits or gains derived by a resident of one of the Contracting States from the alienation of shares or
comparable interests in a company, the assets of which consist wholly or principally of real property situated
in the other Contracting State, may be taxed in that other State.

Article 10
DIVIDENDS (CHINA)
1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting
State may be taxed in that other Contracting State.
2. However, such dividends may also be taxed in the Contracting State of which the company paying the
dividends is a resident and according to the laws of that Contracting State, but if the recipient is the beneficial
owner of the dividends the tax so charged shall not exceed 10 per cent of the gross amount of the dividends

Capital gain :
Gains from the alienation of shares of the capital stock of a company (Indonesia) the property of which
consists directly or indirectly principally of immovable property situated in a Contracting State (Indonesia)
may be taxed in that Contracting State.
Gains from the alienation of any property other than that referred to in the preceding paragraphs shall be
taxable only in the Contracting State of which the alienator is a resident.

Article 10
DIVIDENDS (JAPAN)
1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting
State may be taxed in that other Contracting State.
2. However, such dividends may also be taxed in the Contracting State of which the company paying the
dividends is a resident, and according to the laws of that Contracting State, but if the recipient is the
beneficial owner of the dividends the tax so charged shall not exceed:
(a) 10 percent of the gross amount of the dividends if the beneficial owner is a company which owns at
least 25 percent of the voting shares of the company paying the dividends during the period of twelve
months immediately before the end of the accounting period for which the distribution of profits
takes place;
(b) 15 per cent of the gross amount of the dividends in all other cases.

Capital gain :
 Gains from the alienation of any property other than that referred to in the preceding paragraphs shall be
taxable only in the Contracting State of which the alienator is a resident.

Article 10
DIVIDENDS (MALAYSIA)
1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting
State may be taxed in that other State.
2. Dividends paid by a company which is a resident of Indonesia to a resident of Malaysia may be taxed in
Indonesia in accordance with the laws of Indonesia but if the recipient is the beneficial owner of the dividends
the tax so charged shall not exceed 10% of the gross amount of the dividends.

Capital gain :
Gains from the alienation of shares of a company, the property of which consists principally of immovable
property situated in a Contracting State, may be taxed in that State. Gains from the alienation of an interest
in a partnership or a trust, the property of which consists principally of immovable property situated in a
Contracting State, may be taxed in that State.

Article 10
DIVIDENDS (SINGAPORE)
1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting
State may be taxed in that other State.
2. However, such dividends may be taxed in the Contracting State of which the company paying the dividends is
a resident, and according to the law of that State, but if the recipient is the beneficial owner of the dividends
the tax so charged shall not exceed:
(a) 10% of the gross amount of the dividends if the recipient is a company which owns directly at least 25%
of the capital of the company paying the dividends;
(b) 15% of the gross amount of the dividends in all other cases.

Capital gain : no mention in the treaty

Article 10
DIVIDENDS (TAIWAN)
1. Dividends paid by a company which is a resident of the country of a Contracting Party to a resident of the
country of the other Contracting Party may be taxed in that other country.
2. However, such dividends may also be taxed in the country of the Contracting Party of which the company
paying the dividends is a resident and according to the laws of that country, but if the recipient is the
beneficial owner of the dividends the tax so charged shall not exceed 10% of the gross amount of the
dividends. This paragraph shall not affect the taxation of the company in respect of the profits out of which
the dividends are paid.

Capital gain :
Gains from the alienation of any property other than that referred to in the preceding paragraphs (ed: shares
are not mentioned or referred to in the preceding paragraphs) shall be taxable only in the country of the
Contracting Party of which the alienator is a resident.
 Article 10
DIVIDENDS (THAILAND)

1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting
State may be taxed in that other State.
2. However, such dividends may also be taxed in the Contracting State of which the company paying the
dividends is a resident and according to the laws of that State, but if the recipient is the beneficial owner of
the dividends, the tax so charged shall not exceed:
(i) 15 percent of the gross amount of the dividends if the company paying the dividends engages in an
industrial undertaking;
(ii) 20 percent of the gross amount of the dividends in other cases.

Capital gain :
Gains from the alienation of any property or assets, other than that referred to in the paragraphs 1, 2 and 3 of
this Article and paragraph 4 [of] Article 12, shall be taxable only in the Contracting State of which the
alienator is resident. Nothing in this paragraph shall prevent either Contracting State from taxing the gains or
income from the sale or transfer of shares or other securities.