TMI BlogDividendsX X X X Extracts X X X X X X X X Extracts X X X X ..... f which the company paying the dividends is a resident for the purposes of its tax, and according to the law of that State, but the tax so charged shall not exceed 15 per cent of the gross amount of the dividends. 3. The term dividends in this Article means income from shares and other income which is subjected to the same taxation treatment as income from shares by the laws of the Contracting S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... one of the Contracting States, being dividends to which a person who is not a resident of the other Contracting State is beneficially entitled, shall be exempt from tax in that other State except insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment or fixed base situated in that other State: Provided that this paragraph shall no ..... X X X X Extracts X X X X X X X X Extracts X X X X
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