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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 they arise 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 . 3. The term "" as used in this Ar .....

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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 that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Art .....

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