<h3>Tax Rates</h3><table><tr><th>Item</th><th>Article reference</th><th>Applicable Rates</th><th>Comments</th></tr><tr><td>Dividends</td><td>Article 10(2), Protocol (11)</td><td>5% / 10%</td><td>5% if the beneficial owner is a company holding directly or indirectly at least 10% of voting or total issued shares for 183 days ending on the entitlement date. For dividends paid by a Japanese resident to a Saudi resident, 5% applies only if the holding is in voting shares and the paying company is not entitled to a dividend deduction in Japan. 10% in all other cases.</td></tr><tr><td>Interest</td><td>Article 11(2), 11(3), Protocol (12)</td><td>10%</td><td>0% (residence state only) if beneficially owned by the Government, a political subdivision, local authority, central bank, wholly-owned institution, or for debt-claims guaranteed, insured or indirectly financed by them. Protocol provides 0% (residence state only) for Japanese pension funds on debt-claims arising in Saudi Arabia.</td></tr></table>