Dividends taxation: source withholding limited for beneficial owners, but permanent establishment connections invoke business profit rules. Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, while the source State may also tax such dividends albeit at a limited withholding rate where the recipient is the beneficial owner. Dividends include income from shares and similar profit-participating rights. The source-state withholding limits do not apply when the beneficial owner's holding is effectively connected with a permanent establishment in the source State, in which case business profit rules govern. A State may not tax dividends of its resident company paid to a nonresident except in the specified resident or effectively connected circumstances, nor tax undistributed profits on that basis.