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of <h1>Dividends Taxed in Recipient's State, Limited Tax in Payer's State: 5% for Major Shareholders, 10% Otherwise</h1> Dividends paid by a company in one Contracting State to a resident of another may be taxed in the recipient's state. However, they may also be taxed in the payer's state, with limits if the recipient is a resident of the other state: 5% for companies holding at least 25% of shares, and 10% otherwise. The term 'dividends' covers income from shares and similar rights. Exceptions apply if the recipient has a permanent establishment in the payer's state. A state cannot tax dividends from a company in another state unless paid to its residents or connected to a local establishment.
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