Dividends withholding limits secure reduced cross-border taxation and allocate taxing rights for beneficial owners under the treaty. Dividends paid to a resident of the other Contracting State may be taxed in the recipient's State, while the State of the paying company may also tax such dividends subject to withholding limits where the recipient is the beneficial owner. The withholding limits vary by shareholding status. These limits do not apply if the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the payer's State, in which case rules for business profits or independent personal services apply.