Dividends

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..... laws 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 owns at least 25 per cent of the shares of company paying the dividends;] The following paragraph 1 of Article 8 of the MLI applies .....

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..... the dividends are paid. 3. 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 from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident. 4. The provisions of paragraphs 1 an .....

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..... as such dividends are paid to a resident of that other State or so far 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 .....

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