Dividend withholding limits govern source-state taxation when the recipient is the beneficial owner, with PE connection exceptions.

Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's residence, while the source State may also tax them subject to withholding limitations where the recipient is the beneficial owner; these limits do not affect taxation of the company's profits. Dividends include income from shares and analogous corporate rights. The dividend provisions yield to rules on business profits or independent personal services when the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, and the source State may not tax such dividends or undistributed profits except in the specified cases.

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