TMI BlogDIVIDENDSX X X X Extracts X X X X X X X X Extracts X X X X ..... laws of that State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed: (a) 5 percent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 10 per cent of the capital of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng State of which the company paying the dividends is a resident, 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 dividends are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article ..... X X X X Extracts X X X X X X X X Extracts X X X X
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