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of <h1>Taxation of Cross-Border Dividends: Maximum 5% Rate if Beneficial Owner; Exceptions for Business Presence</h1> Dividends paid by a company resident in one Contracting State to a resident of the other Contracting State may be taxed in the recipient's State. However, the State where the company resides may also tax these dividends, with a maximum tax rate of 5% if the recipient is the beneficial owner. The term 'dividends' includes income from shares and similar rights. The provisions do not apply if the dividend recipient has a business or fixed base in the company's State, in which case other tax rules apply. 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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