OECD Model Tax Convention on Income and on Capital: Condensed Version. Paris, OECD Publishing, 2014. Commentary to Art. 7. § 14. P. 136.
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Ibid. Art. 10. § 1. P. 30: «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».