TMI BlogDividendsX X X X Extracts X X X X X X X X Extracts X X X X ..... at State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed (a) five per cent of the gross amount of the dividends if the beneficial owner is a company which holds directly at least 10 per cent of the capital of the company paying the dividends ; (b) fifteen per cent of the gross amount of the dividends in all other cases. This paragraph shall not af ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ncome from shares by the laws of the Contracting State of which the company making the distribution is a resident. 5. The provisions of paragraphs (1), (2) and (3) shall not apply if the beneficial owner of the dividends, being a resident of the Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ect the companies undistributed profits to a tax on the companies undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. - - statute, statutory provisions legislation, law, enactment, Acts, Rules, Regulations, Taxation Tax Management India - taxmanagementindia - taxmanagement - taxmanagementindia.c ..... X X X X Extracts X X X X X X X X Extracts X X X X
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