TMI BlogArticle 10 - DividendsX X X X Extracts X X X X X X X X Extracts X X X X ..... rticle 10 ] Same right provided in the UN Model Tax Convention. Confers Right to the Source State However, dividends paid by a company which is a resident of a Contracting State may also be taxed in that State according to the laws of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed: ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ffect the taxation of the company in respect of the profits out of which the dividends are paid. [ Para 2 of the Article 10 ] In the UN model Tax convention leaves this percentage to be established through bilateral negotiations. Exception of para 1 and 2 of Article 10 The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... olding in respect of which the dividends are paid is effectively connected with a permanent establishment situated in that other State, nor subject the company s undistributed profits to a tax on the company s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. [ Para 5 of Article 10 ] ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of Para 1 and 2 of Article 10 The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, or performs in that other State independent person ..... X X X X Extracts X X X X X X X X Extracts X X X X
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