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Dividends

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..... a resident and according to the laws 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 as used in this Article means income from shares, mining, shares, founders' shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same t .....

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..... dividends paid by the company, except in so far as such dividends are paid to a resident of that other State or in so far as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment situated in that other State, nor subject the company's undistributed profits to a tax on undistributed profits, even if the dividends paid or the undistributed .....

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