Dividends taxation: treaty limits source withholding for beneficial owners while preserving permanent establishment exceptions. Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, while the source State may tax such dividends subject to a reduced withholding where the beneficial owner is resident of the other State. The term dividends covers income from shares and analogous corporate rights. If the beneficial owner has a permanent establishment or fixed base in the source State and the holding is effectively connected, the provisions on business profits or independent personal services apply instead. The source State may not tax dividends of a resident company deriving income from the other State except in limited connected circumstances, nor tax undistributed profits on that basis.