Artikel VII

It is understood, that if, with respect to dividends as meant in paragraph 3 of Article 10 which are paid by a company which is a resident of the Netherlands, according to the law in force in Venezuela taxation of such dividends in Venezuela will result in a tax burden of less than 10% of the gross amount of the dividends, the Netherlands may, from the date that that law has entered into force, levy a tax not exceeding 10% of the gross amount of the dividends. In case such dividends according to the law in force in Venezuela are considered to be foreign-source income and for that reason exempt from tax in Venezuela, the provisions of Article I of this Protocol shall apply.