this is the international taxation. thank you

Lucifer Company is a company incorporated in Country H, and it has established a wholly owned subsidiary in Country R, namely Gabriel Company. Lucifer Company conducts trading activities for many years, while Gabriel Company manufactures goods since 2008. Based on domestic laws of Country R, outbound dividends, royalties and interest would be subject to a 25% withholding tax. Both Country H and Country R impose tax on residence basis for its residents and source basis for foreigners having income derived within the territory. Currently the corporate income tax rate in Country His 30%. In addition, Country H and Country R have entered into a double tax agreement which is identical to the OECD model. During 2015, Gabriel Company declared and paid dividend of $5,000,000 to Lucifer Company. Required: Critically analyse the Lucifer Company's tax positions in Country H and Country R in respect of the dividends received from Gabriel Company, (30 marks)