Dividends

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....t if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: (1) [MODIFIED by paragraph 1 of Article 8 of the MLI] [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 25 per cent of the capital of the company paying the dividends;] The follo....

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....ll by mutual agreement settle the mode of application of these limitations. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. The term ''dividends'' as used in this Article means income from shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate ri....

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....y which is a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not impose any tax on the dividends paid by the company, except insofar as such dividends are paid to a resident of that other State or insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment or a fixed base ....