Dividend withholding limits under DTAA: reduced source taxation where beneficial owner resides in the other Contracting State. Dividends paid to a resident of the other Contracting State may be taxed in the recipient's State, while the source State may also tax such dividends but withholding is capped where the beneficial owner is a qualifying shareholder (5% if a company holding at least ten percent) or otherwise (10%). The Article defines dividends to include income from shares and equivalent corporate rights. Withholding limits do not apply when the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case the provisions on business profits or independent personal services govern; the source State may not tax undistributed profits.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Dividend withholding limits under DTAA: reduced source taxation where beneficial owner resides in the other Contracting State.
Dividends paid to a resident of the other Contracting State may be taxed in the recipient's State, while the source State may also tax such dividends but withholding is capped where the beneficial owner is a qualifying shareholder (5% if a company holding at least ten percent) or otherwise (10%). The Article defines dividends to include income from shares and equivalent corporate rights. Withholding limits do not apply when the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case the provisions on business profits or independent personal services govern; the source State may not tax undistributed profits.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
