পাতা:বাংলাদেশ গেজেট, অতিরিক্ত, জানুয়ারী ২, ১৯৯৪.pdf/৮

-- SSBBBB BBBS BBBBS BBBS S S - - 3. The provisions of this Article shall also apply, to profits from the participation in a pool, a joint business or an international operating agency. Article 9 Associated Enterprises Where (a) an enterprise of a contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or (b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly. Article 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 which the company paying the dividends is a resiedent and according to the to of that State, but if the recipient is the beneficial owner of the dividends to tax so charged shall not exceed 15 per cent of the gross amount of the dividends. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. The term “dividends" as used in this Article means income from shares, mining shares, founders shares or other rights, not being debt-claims orticipating in profits, as well as income from other corporate rights which is