Dividends

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..... f that State, but if the beneficial owner of the, dividends is a resident of the other Contracting State, the tax so charged shall not exceed: 1) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the capital of the company paying the dividends; 2) 15 per cent of the gross amount of the divide .....

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..... ting State, of which the company paying the dividends is a resident, through a permanent establishment situated therein or performs in that other State independent personal services from a fixed base situated 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 Artic .....

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