TMI BlogDividendsX X X X Extracts X X X X X X X X Extracts X X X X ..... 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 10 per cent of the gross amount of the dividends. This paragraph shall not affect the taxation of the company in respect of the profits out of which dividends are paid. This paragraph shall not affect the taxation of the company in respect of the profits ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t 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 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 tax on the dividends paid by the company ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ecipient is the beneficial owner of the dividends, the tax so charged shall not exceed 15 per cent of the gross amount of the dividends where such dividends relate to contributions made after the entry into force of this Agreement. The paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. - - statute, statutory provisions ..... X X X X Extracts X X X X X X X X Extracts X X X X
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