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The Double Taxation Relief (Taxes on Income) (Morocco) Order 1991

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ARTICLE 10Dividends

(1) Dividends derived from a company which is a resident of the United Kingdom by a resident of Morocco may be taxed in Morocco but, where the dividends are beneficially owned by a resident of Morocco, they shall be exempt from any tax in the United Kingdom which is chargeable on dividends.

(2) Dividends derived from a company which is a resident of Morocco by a resident of the United Kingdom may be taxed in the United Kingdom. Such dividends may also be taxed in Morocco but where the dividends are beneficially owned by a resident of the United Kingdom the Moroccan tax so charged shall not exceed:

(a)10 per cent of the gross amount of the dividends if the beneficial owner is a company which controls at least 10 per cent of the capital of the company paying the dividends;

(b)in all other cases 25 per cent of the gross amount of the dividends.

(3) The provisions of paragraph (1) and (2) of this Article shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, has in the other Contracting State of which the company paying the dividends is a resident, a permanent establishment with which the holding by virtue of which the dividends are paid is effectively connected. In such a case, the provisions of Article 7 shall apply.

(4) Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not impose any tax on the dividends paid by the company to persons who are not residents of that other State, nor subject the undistributed profits of the company to a tax on undistributed profits, even if the dividend paid or the undistributed profits consist wholly or partly of profits or income arising in that other State.

(5) The term “dividends” as used in this Article means income from shares, jouissance shares or jouissance rights, mining shares, founder’s shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights treated as a distribution by the taxation law of the State of which the company making the distribution is a resident.

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