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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Tax on Cross-Border Dividends Capped at 10% for Beneficial Owners Without Permanent Establishments</h1> Dividends paid by a company resident in one Contracting State to a resident of another Contracting State can be taxed in the recipient's State. However, the State where the company is resident may also tax these dividends, but the tax rate should not exceed 10% if the beneficial owner resides in the other State. The term 'dividends' includes income from shares and similar rights. The provisions do not apply if the beneficial owner has a permanent establishment or fixed base in the company's State. Additionally, the other State cannot tax the company's dividends or undistributed profits unless connected to a permanent establishment or fixed base.
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