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DIVIDENDS

Article 10 - Agreement - DTAA - Article 10 - Article 10 1. paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State. 2. However, such may also be taxed in the Contracti .....

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is a company (other than a partnership) which holds directly at least 10 per cent of the capital of the company paying the ; (b) 15 per cent of the gross amount of the in all other cases. The competent- authorities of the Contracting States shall by .....

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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 taxation treatment as income from shares by the laws of the State of which the company making the di .....

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nt, through a permanent establishment 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 are paid is effectively connected with such permanent es .....

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