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3. Where a corporation of one of the contracting States derives profits or income from sources within the other contracting State, there shall not be imposed in that other contracting State any form of taxation on dividends paid by the corporation unless paid to a resident or corporation of that other contracting State, or any tax in the nature of undistributed profits tax on undistributed profits of the corporation, whether or not those dividends or undistributed profits represent, in whole or in part, profits or income so derived.

4. Dividends paid by a corporation of one of the contracting States shall be treated as income from sources within that contracting State.

1. The amount of tax imposed by one of the contracting States on any interest derived from sources within that contracting State by a resident or corporation of the other contracting State, not having a permanent establishment situated in the former contracting State, shall not exceed 15 percent of the amount of such interest.

2. The term "interest" as used in the present Article means interest on bonds, securities, notes, debentures or any other form of indebtedness (including mortgages or bonds secured by real property).

3. Interest on

(a) bonds or debentures issued by one of the contracting States, including local governments thereof, or by a corporation of one of the contracting States, or

(b) deposits made in one of the contracting States shall be treated as income from sources within that contracting State.

4. Interest on loans in connection with trade, business or other transactions carried on in one of the contracting States by

(a) a resident or corporation of that contracting State,

(b) an enterprise of the other contracting State, having a permanent establishment in the former contracting State shall be treated as income from sources within the former contracting State.

1. Salaries, wages, pensions or similar compensation paid by one of the contracting States in respect of services rendered to that contracting State in the discharge of