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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Dividends Taxed at Maximum 5% or 15% Based on Shareholding, Excluding Permanent Establishment Cases</h1> Dividends paid by a company in one Contracting State to a resident of another may be taxed in the recipient's state. However, the state where the company resides may also tax these dividends, but the tax must not exceed 5% if the recipient company holds at least 10% of the paying company's capital, or 15% in other cases. The term 'dividends' includes income from shares and similar rights. These provisions do not apply if the dividends are connected to a permanent establishment or fixed base in the paying company's state. A state cannot tax a company's dividends or undistributed profits unless they are connected to a permanent establishment or fixed base within that state.
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