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| Spefic
Notes |
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| (a) Shareholding
at least 25% |
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| (a)1
Shareholding at least 20% |
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| (a)2
Shareholding at least 15% |
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| (b)
Shareholding at least 10% |
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| (b)1
Shareholding less than 25% |
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| (c)
Interest taxed in recipient's country of residence but many also be taxed in source
country according to the laws of the state. |
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| (d) Gains from the alienation of property (movable and immovable)
forming part of the business property of a permanent establishment may be taxed
in the country where the permanent established is situated. Gains from alienation
of ships or aircraft are taxable in the state in which the alienator is resident. |
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| (e) Dividends/Interests/Royalties
are taxable only in the recipient's country of residence according to the law
of the state. |
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| (f)
Treaty applicable only for Offshore Companies. |
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| (g) Gains from the alienation of shares of a company may
be taxed in the company's country of residence. |
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| (h) Gains from alienation of any property (inc. shares) derived
by an individual holding "dual" residence are subject to taxation at any time
during the next ten years following the date on which the individual has ceased
to de a resident of the first state of which he was a resident. |
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| (i) Dividends derived by a company
resident in Luxembourg from Mauritanian sources are exempt from tax in Luxembourg
provided that the Luxembourg company holds at least 10% of the shareholding of
the Mauritian company and that the latter is subjected to tax of at least 15%
in Mauritius. |
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| (j)
Dividends paid by a company which is resident of Malaysia to a resident of Mauritius
who is the beneficial owner are exempt from any tax in Malaysia which is chargeable
on dividends. |
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| (k)
Such tax shall be deemed to have been paid at an amount not exceeding 15% of the
gross amount of the dividends. |
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| (l) In the case of copyright of literary, artistic or scientific
work, excluding cinematographic films, tapes or discs for radio or television
broadcasting. |
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| (m)
In the case of interest paid being effectively connected with a permanent establishment,
the beneficial owner of the interest is taxed at a minimum of 5%. |
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