Dividends

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....he dividends is a resident, and 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 co....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e distribution is a resident. (b) In this Article, the 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, ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....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 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 n....