Dividends

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..... s of that State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed: (a) [ MODIFIED by paragraph 1 of Article 8 of the MLI ] [15 per cent of the gross amount of the dividends if the beneficial owner is a company which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividends;] The following paragraph .....

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..... of the company on the profits out of which the dividends are paid. 4. The term 'dividends' as used in this Article means income from shares or other rights, not being debt-claims, participating in profits, as well as income assimilated to income from shares by the taxation law of the State of which the company making the distribution is a resident. 5. The provisions of paragraphs 1 and 2 .....

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..... ividends are paid to be a resident of that other State or insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment or a fixed base situated in that other State, nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholl .....

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