Dividends

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.... that State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed : (a) five per cent of the gross amount of the dividends if the beneficial owner is a company which holds directly at least 10 per cent of the capital of the company paying the dividends ; (b) fifteen per cent of the gross amount of the dividends in all other cases. This paragraph sh....

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.... taxation treatment as income from shares by the laws of the Contracting State of which the company making the distribution is a resident. 5. The provisions of paragraphs (1), (2) and (3) shall not apply if the beneficial owner of the dividends, being a resident of the Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, th....