TaxTMI 
TaxTMI 
Article 10 - Dividends
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....ght provided in the UN Model Tax Convention. Confers Right to the Source State * However, dividends paid by a company which is a resident of a Contracting State may also be taxed in that State according 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) 5 per cent of the gross amount ....
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.... dividends are paid. [ Para 2 of the Article 10 ] * In the UN model Tax convention leaves this percentage to be established through bilateral negotiations. Exception of para 1 and 2 of Article 10 * The provisions of paragraphs 1 and 2 shall not apply * if the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of wh....
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....ed in that other State, * nor subject the company's undistributed profits to a tax on the company's undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. [ Para 5 of Article 10 ] Meaning of Dividends * The term "dividends" as used in this Article means income from * shares, "jouissance" shar....