МЕЖДУ ПРАВИТЕЛЬСТВОМ РОССИЙСКОЙ ФЕДЕРАЦИИ И ПРАВИТЕЛЬСТВОМ БОЛИВАРИАНСКОЙ РЕСПУБЛИКИ ВЕНЕСУЭЛА ОБ ИЗБЕЖАНИИ ДВОЙНОГО НАЛОГООБЛОЖЕНИЯ И ПРЕДОТВРАЩЕНИИ УКЛОНЕНИЯ ОТ НАЛОГООБЛОЖЕНИЯ В ОТНОШЕНИИ НАЛОГОВ НА ДОХОДЫ И КАПИТАЛ. Конвенция. Правительство РФ. 22.12.03

Article 10
                              Dividends

     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.
     2.  However,  such dividends may also be taxed in the Contracting
State  of  which  the  company  paying the dividends is a resident and
according  to  the  laws  of  that  State, but if the recipient is the
beneficial owner of the dividends the tax so charged shall not exceed:
     a)  10  percent  of  the  gross  amount  of  the dividends if the
beneficial  owner  is a company (other than a partnership) which holds
directly at least 10 per cent of the capital of the company paying the
dividends  and  has  invested  in  this  company  not  less  than  the
equivalent of 100.000 US dollars;
     b)  15  percent of the gross amount of the dividends in all other
cases.
     This  paragraph  shall  not affect the taxation of the company in
respect of the profits out of which the dividends are paid.
     3. The term "dividends" as used in this Article means income from
shares  or  other  rights,  not  being  debt-claims,  participating in
profits,  as  well  as  income  from  other  corporate rights which is
subjected  to the same taxation treatment as income from shares by the
laws  of  the  State of which the company making the distribution is a
resident.
     4.  The  provisions  of paragraphs 1 and 2 shall not apply if the
beneficial  owner  of the dividends, being a resident of a Contracting
State, carries on business in the other Contracting State of which the
company  paying  the  dividends  is  a  resident,  through a permanent
establishment  situated  therein,  or  performs  in  that  other State
independent  personal services from a fixed base situated therein, and
the  holding in respect of which the dividends are paid is effectively
connected  with  such  permanent  establishment or fixed base. In such
case  the  provisions  of Article 7 or Article 14, as the case may be,
shall apply.
     5.  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,
except  insofar as such dividends are paid to a resident of that other
State  or insofar as the holding in respect of which the dividends are
paid  is  effectively  connected  with  a permanent establishment or a
fixed  base  situated  in  that other State, nor subject the company`s
undistributed profits to a tax on the company`s undistributed profits,
even if the dividends paid or the undistributed profits consist wholly
or partly of profits or income arising in such other State.