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Dividend Transfer Transactions

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..... such dividends may be taxed, provided that the beneficial owner or the recipient is a company which is a resident of the other Contracting Jurisdiction and which owns, holds or controls more than a certain amount of the capital, shares, stock, voting power, voting rights or similar ownership interests of the company paying the dividends, shall apply only if the ownership conditions described in th .....

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..... paragraph 1 already include: i) a minimum holding period; ii) a minimum holding period shorter than a 365 day period; or iii) a minimum holding period longer than a 365 day period. 4. Each Party that has not made a reservation described in subparagraph a) of paragraph 3 shall notify the Depositary of whether each of its Covered Tax Agreements contains a provision described in paragraph 1 that is n .....

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