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of <h1>Tax on Cross-Border Dividends Capped at 10% for Beneficial Owners; Permanent Establishment Exception Applies</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. The State where the company is resident may also tax these dividends, but if the recipient is the beneficial owner, the tax shall not exceed 10% of the gross dividends. 'Dividends' include income from shares and similar rights. Provisions do not apply if the recipient conducts business through a permanent establishment in the company's State. A State cannot tax dividends paid by a company resident in another State unless paid to its residents or connected to a permanent establishment.
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