Dividend

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....s 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: 1) 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, 2) 15 per cent of the gross a....

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.... State, carries on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, or performs in the 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....