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of <h1>Tax Cap on Cross-Border Dividends: Max 7.5% if Beneficial Owner Resides in Other State; Exceptions Apply.</h1> Dividends paid by a company resident in one Contracting State to a resident of the other may be taxed in the recipient's state. However, they may also be taxed in the state of the paying company, but the tax cannot exceed 7.5% if the beneficial owner resides in the other state. The term 'dividends' includes income from shares or similar rights. Exceptions apply if the beneficial owner conducts business through a permanent establishment in the paying company's state. In such cases, Articles 7 or 14 apply. A state cannot tax dividends from a company resident in the other state unless specific conditions are met.
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