Dividends

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....rding to the laws of that 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 holds directly 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 i....

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....performs in that other State independent personal services from a fixed base situated therein, and the holding, in respect of which, the dividends are paid, is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or 14, as the case may be, shall apply. 5. Where a company which is a resident of a Contracting State derives profits or inc....