(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 recipient is the beneficial owner of the dividends the tax so charged shall not exceed:
(a)5 per cent. of the gross amount of the dividends if the beneficial owner is a company which controls directly at least 25 per cent. of the voting power in the company paying the dividends;
(b)15 per cent. of the gross amount of the dividends in all other cases.
This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid.