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Dividends

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..... that State, but the tax so charged shall not exceed : (a) 5 per cent of the gross amount of the dividends if the recipient is a company which owns at least 25 per cent of the shares of the company paying the dividends during the period of six months immediately preceding the date of payment of the dividends ; (b) 15 per cent of the gross amount of the dividends in all other cases. 3. The ter .....

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..... . 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 to persons who are not residents of that other State, or subject the companies undistributed profits to a tax on undistributed profits, even if the dividends paid on the undistributed profits consist wh .....

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