Dividend taxation limited by treaty; source-state levy capped for non-resident beneficial owners, with permanent establishment exceptions. Dividends paid by a company resident in one Contracting State to a resident of the other State may be taxed in the recipient's State, while the State of residence of the paying company may also tax those dividends subject to a treaty ceiling where the beneficial owner is resident of the other State. The Article defines 'dividends' to include income from shares and similar participatory rights and excludes the reduced source-state treatment where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case business profits or personal services provisions apply.