The protocol provides for a zero withholding tax in respect of inter-company dividends. The application of the zero rate essentially requires that (i) the beneficial owner is a company resident of the other contracting state that has owned, directly or indirectly, through one or more residents of either contracting states, shares representing 80% or more of the voting power in the company paying the dividends for at least a 12-month period ending on the date on which the entitlement to the dividends is determined and (ii) certain conditions under the tax treaty's limitation-on-benefits clause are met. Under certain conditions, pension...