Artikel VII

1. It is understood that income received in connection with the (partial) liquidation of a company or a purchase of own shares by a company is treated as dividends.
2. Notwithstanding the provisions of paragraphs 1, 2, and 5 of Article 10, dividends paid by a company which under the laws of a Contracting State is a resident of that State, to an individual who is a resident of the other Contracting State and who upon ceasing to be a resident of the first-mentioned State is taxed on the appreciation of capital as meant in paragraph 3 hereunder, may also be taxed in that State in accordance with the laws of that State, but only insofar as the assessment on the appreciation of capital is still outstanding.
3. Where an individual has been a resident of a Contracting State and has become a resident of the other Contracting State, the provisions of paragraph 4 of Article 13 shall not prevent the first-mentioned State from taxing under its domestic law the capital appreciation of shares, profit sharing certificates, call options and usufruct on shares and profit sharing certificates, in and debt-claims on a company for the period of residency of that individual in the first-mentioned State. In such case, the appreciation of capital taxed in the first-mentioned State shall not be included in the tax base when determining the appreciation of capital by the other State.