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C. HOLDING COMPANIES

127. Local Holding Company controlling One or More Subsidiaries abroad. — There are no holding companies established in N.E.I. which control foreign subsidiary companies, but, if they existed, they would be taxable on their dividends or other income received from foreign subsidiaries (see paragraph 63).

128. Local Subsidiary controlled by a Foreign Holding Company. — No tax is imposed on dividends paid by a local subsidiary to a foreign holding company (see paragraphs 32 and 42). Profits diverted from a subsidiary to a foreign parent may be taxed as described in paragraph 96.

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