Document ID: chunk:federal_register_of_legislation:C2004A01208:schedule:1:p12
Version: federal_register_of_legislation:C2004A01208
Segment Type: schedule
Provision Reference: sch 1 (pt 12/12)
Character Range: 33375–34562

available under this Article if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the shares or other rights in respect of which the dividend is paid to take advantage of this Article by means of that creation or assignment.

8 For the purposes of paragraph 3 of this Article, the term "principal class of shares" means the ordinary or common shares of the company, provided that such class of shares represents the majority of the voting power and value of the company.  If no single class of ordinary or common shares represents the majority of the voting power and value of the company, the "principal class of shares" is that class or those classes that in the aggregate represent a majority of the voting power and value of the company.

ARTICLE 11

Interest

1 Interest arising in a Contracting State and beneficially owned by a resident of the other Contracting State may be taxed in that other State.

2 However, that interest may also be taxed in the Contracting State in which it arises, and according to the law of that State, but the tax so charged shall not exceed 10 per cent of the gross amount of the interest.