Dividend taxation limited by treaty to reduced source-state levy where beneficial owner is resident; permanent establishment connection overrides. Dividends paid by a company resident in one Contracting State to a resident of the other State may be taxed in the recipient's State; the source State may also tax such dividends but where the beneficial owner is resident in the other State the source tax is limited to a specified maximum of the gross dividend. The limitation is subject to an exception when the beneficial owner carries on business through a permanent establishment or performs independent personal services from a fixed base in the source State and the holding is effectively connected, in which case rules on business profits or independent personal services apply. The treaty also restricts the other State from taxing dividends paid by a resident company or taxing undistributed profits except in the stated exceptions.