TMI BlogDIVIDENDSX X X X Extracts X X X X X X X X Extracts X X X X ..... ng 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 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 the dividends are paid. 3. The term "dividends" as used in this Article ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vices 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 State derives profits or income from the other Contracting State, th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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