Dividends taxation: withholding capped based on beneficial owner status and entity type, with treaty allocation rules for establishments.

Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, and the source State may also tax such dividends but must abide by treaty limits on withholding where the recipient is the beneficial owner. Reduced withholding depends on ownership and entity type, with specific rules for regulated investment companies and real estate investment trusts. Where dividends are attributable to a permanent establishment or fixed base, business profits or independent personal services rules apply instead.

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