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of <h1>Dividends Taxed Up to 10% in Company's State, Unless Business Conducted via Permanent Establishment (Articles 7 or 15).</h1> Dividends paid by a company resident in one Contracting State to a resident of the other Contracting State may be taxed in the recipient's State. Additionally, these dividends can be taxed in the company's resident State, but if the recipient is the beneficial owner, the tax should not exceed 10% of the gross amount. 'Dividends' include income from shares and similar rights. The provisions do not apply if the beneficial owner conducts business in the company's State through a permanent establishment or fixed base, where Articles 7 or 15 will apply instead.
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