Dividends

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....cording to the law of that State, but the tax so charged shall not exceed: (a) 10 per cent of the gross amount of the dividends if the recipient is a company which owns at least 10 per cent of the shares of the company paying the dividends during the period of six months immediately preceding the date of payment of the dividends; (b) 15 per cent of the gross amount of the dividends in all other ....

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....ng in respect of which the dividends are paid is effectively connected with such permanent establishment of fixed base. In such a case the provisions of Article 7 or Article 16, as the case may be, shall apply. 5. Where a company which is a resident of a Contracting State, derives profits or income from the other Contracting State, that other state may not impose any tax on the dividends paid by ....