Dividends

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....according to the laws of that State, but if the beneficial owner of the dividends is a company which is a resident of the other ContractingState, the tax shall not exceed- (a) 15 per cent of the gross amount of dividends, in a case where the company paying the dividends is engaged in an industrial undertaking and the beneficial owner of the dividends is a company of the other Contracting State ow....

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.... term "industrial undertaking" means an undertaking falling under any of the classes mentioned below : (i) manufacturing, assembling and processing; (ii) construction, civil engineering and ship building; (iii) production of electricity, hydraulic power or gas or the supply of water; (iv) agriculture, forestry and fishery and the carrying on of a plantation; (v) any other undertaking entitled....

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....ed with such permanent establishment or fixed base. In such a case, the provisions of Article 7 or Article 14, 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 the company, except in so far as such dividends are paid to a reside....