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5.6. Qualification of Specific Income Categories for Tax Purposes


The term “dividend” includes all distributions made to shareholders including capital distributions.

Certain payments are deemed to be dividends, such as liquidation proceeds, subject to certain conditions.


The term “royalty” includes payments of any nature received as consideration for the use of or right to use any:

  • copyright to a literary, artistic or scientific work, including feature films and films and tapes for radio;
  • television programmes,
  • any patent, trademark, pattern or model, drawing, secret formula or secret processing method;
  • information on the industrial, commercial or scientific experience.