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DIVIDENDS

Article 10 - 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 Contracting State of which the company paying the is a resident and according to the laws of that State, but if the recipient is the beneficial owner of the the tax so charged shall not exceed: (a) 5 percent of the gross amount of the if the beneficial owner is a company .....

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her 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 distribution is a resident. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the , being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the is a resident, through .....

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