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of <h1>Tax on Cross-Border Dividends Capped at 5% for Major Shareholders, 10% for Others Under Specific Conditions</h1> Dividends paid by a company resident in one Contracting State to a resident of the other Contracting State can be taxed in the recipient's state. Additionally, they may be taxed in the payer's state, but if the beneficial owner resides in the other state, the tax is capped at 5% for companies owning at least 25% of the shares, and 10% for others. The term 'dividends' includes income from shares and similar rights. Exceptions apply if the beneficial owner operates a business or provides services in the payer's state through a permanent establishment. Profits from a company in one state cannot be taxed on dividends by the other state unless connected to a permanent establishment.
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