S.L. 123.111 Art. 5beneficial owner the other Party of a permanent personal of which the establishment or the case may be,

The provisions of paragraphs 1 and 2 shall not apply if the of the dividends, being a resident of a Party, carries on business in which the company paying the dividends is a resident, through establishment situated therein, or performs in that other Party independent services from a fixed base situated therein, and the holding in respect dividends are paid is effectively connected with such permanent fixed base. In such case the provisions of Article 7 or Article 14, as shall apply.