TMI BlogDividendsX X X X Extracts X X X X X X X X Extracts X X X X ..... at 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 which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividends; (b) 25 per cent of the gross amount of the dividends in all other cases. 3. Th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uated 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, shall apply. 6. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not impose any ta ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
