hamonyX-Corp
Art.10 Dividends
Art.10(4) : PE Proviso
Dividend rules are
Company X P.E.
stimulated
Art.10 Dividends
Do Art.10 apply to this Ca as below? If not, which
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商谈Company X P.E.
X Co P.E.Y Co Company Ylbt
2014/5/8
Attached: Art.10 Dividends Attached: Art.10 Dividends
1. Dividends 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 dividends may also be taxed in the Contracting State of
State A
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Company X
P .E.
Company Y
Art.7 shall apply
2014/5/8Company Y
PE
career
Company X
Art.21 shall apply
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Company Y
PE
Company X
Art.11 Interest
2014/5/8Art.11 Interest
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