Dividends: source-state tax limited to 10% when the beneficial owner is a resident of the other Contracting State. Dividends paid by a resident company of one Contracting State to a resident of the other may be taxed in the recipient's State, and also in the source State but limited to 10 per cent of the gross amount when the beneficial owner is a resident of the other State. 'Dividends' covers income from shares and similar participatory corporate rights (not debt-claims). The withholding limit does not apply 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 independent personal services rules govern; the source State also generally may not tax dividends or undistributed profits except as specified.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Dividends: source-state tax limited to 10% when the beneficial owner is a resident of the other Contracting State.
Dividends paid by a resident company of one Contracting State to a resident of the other may be taxed in the recipient's State, and also in the source State but limited to 10 per cent of the gross amount when the beneficial owner is a resident of the other State. "Dividends" covers income from shares and similar participatory corporate rights (not debt-claims). The withholding limit does not apply 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 independent personal services rules govern; the source State also generally may not tax dividends or undistributed profits except as specified.
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