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....icles 10, 11, 12 and 13 (a) Notwithstanding the provisions of this Agreement, a company resident in a Contracting State in which persons who are not residents of that State hold, directly or indirectly, a participation of more than 50 per cent of the share capital, shall not be entitled to the relieves provided for by the Agreement in respect of dividends, interest, royalties and capital gains a....