Withholding tax caps on cross border dividends, interest and royalties limited by amended treaty protocol, with transitional application rules. Amendments replace Articles 10(2), 11(2) and 12(2) to impose a ten per cent withholding tax cap on dividends, interest and royalties/fees for technical services when the recipient is the beneficial owner, while preserving the source state's taxation of the payer's profits. The Protocol deletes sub paragraph (c) of Article 23(3) and sets entry into force and transitional application dates for each Contracting State; the Central Government directed implementation domestically to give effect to the Protocol from the notified effective date.
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Withholding tax caps on cross border dividends, interest and royalties limited by amended treaty protocol, with transitional application rules.
Amendments replace Articles 10(2), 11(2) and 12(2) to impose a ten per cent withholding tax cap on dividends, interest and royalties/fees for technical services when the recipient is the beneficial owner, while preserving the source state's taxation of the payer's profits. The Protocol deletes sub paragraph (c) of Article 23(3) and sets entry into force and transitional application dates for each Contracting State; the Central Government directed implementation domestically to give effect to the Protocol from the notified effective date.
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