Ad Article 10 Sample Clauses

Ad Article 10. It is understood that the provisions of Article 10 shall not apply, if the relation between the company paying the dividends and the receiving company has been established or maintained mainly for purposes of taking advantage of the benefits provided for in this Article.
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Ad Article 10. 1. Notwithstanding paragraph 2 of Article 10, the Contracting State of which the company is a resident shall not levy a tax on dividends paid by that company, if the beneficial owner of the dividends is a pension fund or a collective investment vehicle referred to in paragraph 2 of Article 4. 2. If after the date of signature of this Agreement in any Agreement for the avoidance of double taxation concluded by the Netherlands with a third State, the Netherlands would agree to a lower rate for dividends as provided in paragraph 2, subparagraph (b) of article 10, then the lower rate shall automatically apply to residents of Qatar from the moment the lower rate is effective for residents of that third State.
Ad Article 10. 1. Notwithstanding paragraph 2 of Article 10, the Contracting State of which the company is a resident shall not levy a tax on dividends paid by that company, if the beneficial owner of the dividends is a pension fund referred to in paragraph 2 of Article 4. 2. It is understood that, for the purposes of this Convention, a) the term “jouissance shares” means securities that grant the right to participate in the net profit of the company and do not represent capital of the company but represent a non financial contribution, such as a contribution in know how; b) the term “jouissance rights” means rights, whether or not documented by official papers, to participate in the net profit of the company, that do not represent capital of the company but represent a non financial contribution, such as a contribution in know how; c) the term “mining shares” means shares in a mining company subject to mining law and organised in a specific legal form; d) the term “founders’ shares” means shares that are issued as remuneration for services rendered by founders during the constitution of a company and do not represent capital of the company.
Ad Article 10. The provisions of paragraph 3 of Article 10 shall not apply to a person who is a fiscal investment institution (Fiscale Beleggingsinstelling) for the purposes of the corporation tax of the Netherlands.
Ad Article 10. 1. For so long as, under the provisions of Belgian law referred to in paragraph 2 (c), first sentence of Article 23, dividends derived by a company which is a resident of Belgium from a company which is a resident of Vietnam are exempt from corporate income tax in Belgium, the percentage provided for in paragraph 2 (b) of Article 10 shall be reduced to 7 per cent of the gross amount of the dividends. 2. The limitation provided for in paragraph 2 of Article 10 includes in the case of Vietnam the profit remittance tax.
Ad Article 10. Notwithstanding paragraph 2 of Article 10, the Contracting State of which the company is a resident shall not levy a tax on dividends paid by that company, if the beneficial owner of the dividends is a pension fund or a collective investment vehicle referred to in paragraph 2 of Article 4.

Related to Ad Article 10

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