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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 beneficial owner of the is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the . This par .....

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pply 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 a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the holding it n respect of which the are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Arti .....

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