TaxTMI Login
Just a moment...
AI-powered research trained on the authentic TaxTMI database.
Launch AI Search →Powered by Weblekha - Building Scalable Websites
Press 'Enter' to add multiple search terms. Rules for Better Search
of 
Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
All Acts & Rules
of Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
All Acts & Rules
Note
Bookmark
Share
Don't have an account? Register Here
of Press 'Enter' after typing page number.
<h1>Dividend withholding limited where beneficial owner is resident, with source-state tax subject to treaty cap and PE exceptions.</h1> Article 10 permits taxation of dividends in the recipient's State while allowing the source State to tax dividends paid by its resident company subject to a treaty ceiling when the beneficial owner is resident in the other State. The provision defines dividends as income from shares and equivalent corporate rights and excludes the withholding limitation where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case business or service income rules apply. The Article also restricts the other State from taxing dividends or undistributed profits except as specified.
TaxTMI 
TaxTMI 
