Dividends

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.... 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) 15 per cent of the gross amount of the dividends if the beneficial owner is a company which owns at least 10 per cent of the shares of the company paying the dividends; (b) 25 per cent of the gross amount of the dividends in all other cas....

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....of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein or 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 ....