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 15 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 the dividends are paid. 3. The term dividends as used in this Article means income from shares, jouissance shares or jouissance rights, fou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment. In such case, the provisions of Article 7 shall apply. - - statute, statut ..... X X X X Extracts X X X X X X X X Extracts X X X X
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