Dividend taxation: source state may tax dividends but withholding on cross-border dividends limited when beneficial owner resides in other state. Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, while the payer's State may also tax them but withholding is limited when the beneficial owner resides in the other State. 'Dividends' means income from shares or similar profit-participating rights. The dividend rules do not apply where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the payer's State, in which case business profits or independent personal services provisions govern; a State may not tax dividends or undistributed profits arising abroad except in specified connected situations.
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.
Dividend taxation: source state may tax dividends but withholding on cross-border dividends limited when beneficial owner resides in other state.
Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, while the payer's State may also tax them but withholding is limited when the beneficial owner resides in the other State. "Dividends" means income from shares or similar profit-participating rights. The dividend rules do not apply where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the payer's State, in which case business profits or independent personal services provisions govern; a State may not tax dividends or undistributed profits arising abroad except in specified connected situations.
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