| 1 | the beneficial owner of the dividends is a company which is a resident of the other State that has owned directly shares representing at least 80 percent of the voting power in the company paying the dividends for a 12-month period ending on the date the dividend is declared; and: | |
| 2 | … |
OrbitaxThe protocol has been ratified by both states but has not yet entered into force. However, it is expected that the exchange of ratification instruments will take place timely as a result of which the protocol will be effective as from 1 January 2005.
Under the protocol, the withholding tax on dividends will be 0% if the following requirements are met: