Dividends

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.... (a) if the dividends are paid by a company that is a resident of India to a resident of Malta who is the beneficial owner thereof, the tax charged by India shall not exceed 10 per cent of the gross amount of the dividends; (b) if the dividends are paid by a company that is a resident of Malta to a resident of India who is the beneficial owner thereof, the tax charged by Malta on the gross amo....

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....pany paying the dividends 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, ....