Dividend withholding limits set by treaty restrict source-state taxation of dividends when beneficial owner is non-resident. Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, and the State of residence of the paying company may also tax such dividends but, where the beneficial owner is resident of the other State, the source-state's tax is limited by treaty. 'Dividends' includes income from shares and analogous corporate rights. The treaty's reduced taxing rights do not apply if the beneficial owner's holding is effectively connected with a permanent establishment or a fixed base in the payer's State, in which case the rules on business profits or independent personal services govern. The other State may not tax dividends or undistributed profits derived from it except as to residents or effectively connected holdings.