Dividends

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.... to the laws of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (a) Five (5) per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least twenty five (25) per cent of the share capital of the company paying the dividends....

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....nds is a resident, through a permanent establishment situated therein, or performs in that other State independent personal services from a 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 case the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Whe....