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Article 12 - Agreement - DTAA - Article 12 - Article 12 1. arising in a Contracting State and paid 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 in which the .....

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ticle means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph film, or films or tapes used for television or radio broadcasting, any pa .....

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ns of paragraph 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 in which the arise, through a permanent establishment situated therein, or performs in .....

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icle 7 or Article 14, as the case may be, shall apply 5. shall be deemed to arise in a Contracting State when the payer is that State itself, a political sub-division, a local authority, or a resident of that State. Where, however, the person paying .....

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