Dividends

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..... , 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 owns at least ten per cent of the shares of the company paying the dividend; and (b) 10 per cent of the gross amount of the dividends in all other cases. This paragraph shall not affect the taxation of t .....

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..... d therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not impose any tax on th .....

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