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Dividends

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..... t of that dividend, tax may also be charged in the United Kingdom and according to the laws of the United Kingdom on the aggregate of the amount or value of the dividend and the amount of the tax credit, at a rate not exceeding 15 per cent. (c) Except as provided in sub-paragraph (b) of this paragraph a dividend derived from a company which is a resident of the United Kingdom by a resident of Indi .....

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..... directly or indirectly at least 10 per cent. of the voting power in the company paying the dividend. For this purpose two companies shall be deemed to be associated if one is controlled directly or indirectly by the other, or both are controlled directly or indirectly by a third company. 4. A dividend paid by a company which is a resident of India to a resident of the United Kingdom may be taxed .....

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..... aid is effectively connected. In such a case the provisions of Article 7 (Business profits) or Article 15 (Independent personal services), as the case may be, shall apply. 7. 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 the dividends paid by the company, except insofar as such divi .....

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..... ther than interest which falls within the provisions of Article 12) treated as a dividend or distribution under that law. 9. As used in paragraph 4 of this Article the term new contribution means any share capital, other than bonus shares, issued after the date of entry into force of this Convention by a company which is a resident of India, and beneficially owned by a resident of the United Kingd .....

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