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ARTICLE 16

U.S. Income Tax Treaty — Trinidad Tax Treaty · 2026-10-03 edition · updated 2026-10-04 · United States

Investment or Holding Companies

A corporation of one of the Contracting States deriving dividends, interest, or royalties from sources within the other Contracting State shall not be entitled to the benefits of Article 12 (Dividends), 13 (Interest), or 14 (Royalties) if (a) By reason of special measures granting tax benefit to investment or holding companies the tax imposed on such corporation by the first-mentioned Contracting State with respect to such dividends, interest, or royalties is substantially less than the tax generally imposed by such Contracting State on corporate profits, and,

(b) Twenty-five percent or more of the capital of such corporation is held of record or is otherwise determined, after consultation between the competent authorities of the Contracting States, to be owned, directly or indirectly, by one or more persons who are not residents of the first-mentioned Contracting State (or, in the case of a Trinidad and Tobago corporation, who are citizens of the United States).

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▸Contents — U.S. Income Tax Treaty — Trinidad Tax Treaty

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