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      <description>Dividends paid by a company resident of one Contracting State to a resident of the other may be taxed in the recipient&#039;s State and may also be taxed in the State of the paying company, but where the beneficial owner is a resident of the other State the tax charged by the source State is limited; dividends are defined to include income from shares and similar corporate rights, and the withholding limitation does not apply where the beneficial owner&#039;s holding is effectively connected with a permanent establishment or fixed base, in which case articles on business profits or independent personal services apply.</description>
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