Dividends

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....the beneficial owner of the dividends is a resident of the other Contracting State, 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 voting stock of the company paying the dividends. (b) 25 per cent of the gross amount of the dividends in all other cases. Sub-paragraph (b) and ....

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....es by the taxation laws of the State of which the company making the distribution is a resident; and income from arrangements, including debt obligations, carrying the right to participate in profits, to the extent so characterised under the laws of the Contracting State in which the income arises. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, b....