CONVENTION BETWEEN

DIVIDENDS 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 State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed 5 per cent 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. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3.  Dividends paid by a company which is a resident of a Contracting State to the Government of the other Contracting State shall be taxable only in that other Contracting State. For the purposes of this paragraph, the term ”Government” shall include: a)  in the case of Georgia: i)  the Government, administrative subdivisions or local authorities; ii)  the National Bank of Georgia; and iii)  any other entity wholly owned by the Government; b)  in the case of the Kingdom of Saudi Arabia: i)  the Saudi Arabia Monetary Agency (SAMA); ii)  the Saudi Fund for Development; iii)  the Public Investment Fund; iv)  the Public Pension Agency; v)  the General Organization for Social Insurance, and vi)  any other entity wholly owned by the Government. 4.  The term “dividends” as used in this Article means income from shares, “jouissance” shares or “jouissance” rights, mining shares, founders’ shares or other rights not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident. 5.  The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident through a permanent establishment situated therein or performs in that other State independent personal services from a fixed base situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 6.  Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not impose any tax on the dividends paid by the company, except insofar as such dividends are paid to a resident of that other State or insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment or a fixed base situated in that other State, nor subject the company›s undistributed profits to a tax on the company›s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.