TMI BlogDIVIDENDSX X X X Extracts X X X X X X X X Extracts X X X X ..... and according to the laws 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: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which owns at less: 10 per cent of the shares of the company paying the dividends; (b) 10 per cent of the gros ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... situated therein, or performs in that other State independent personal services from a fixed base situated 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. 5. Where a company which is a resident of a Contracting Sta ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
