TMI BlogDividendsX X X X Extracts X X X X X X X X Extracts X X X X ..... ent, and according to the laws of that State, but if the recipient is the beneficial owner of the dividends, the tax so charged shall not exceed: (a) 15 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 and the dividends are attributable to a ne ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 15, as the case may be, shall apply. 5. Where a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... date of entry into force of this Convention by a company which is a resident of a Contracting State, and beneficially owned by a resident of the other Contracting State. - - statute, statutory provisions legislation, law, enactment, Acts, Rules, Regulations, Taxation Tax Management India - taxmanagementindia - taxmanagement - taxmanagementindia.com - TMI - TaxTMI - TMITax - Double Tax Avoidanc ..... X X X X Extracts X X X X X X X X Extracts X X X X
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