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TMI BlogDividendsX X X X Extracts X X X X X X X X Extracts X X X X ..... at State, but if the recipient is the beneficial owner of the dividends, the tax so charged shall not exceed: (a) 10 per cent of the gross amount of the dividends if the beneficial owner is a company which owns at least 25 per cent of the shares of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. This paragraph shall not affect the taxation ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the company making the distribution is a resident. 5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein or performs in that other State independent persona ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... istributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. 7. (a) Dividends shall be deemed to arise in India if they are paid by a company which is a resident of India; (b) Dividends shall be deemed to arise in Singapore: (i) if they are paid by a company which is a resident of Singapore; or (ii) if they a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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