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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Dividends Taxed in Recipient's State; Capped at 5% or 15% If Beneficial Owner Under Certain Conditions</h1> Dividends paid by a company in one Contracting State to a resident of another Contracting State may be taxed in the recipient's State. However, the State where the company resides can also tax these dividends, but if the recipient is the beneficial owner, the tax is capped at 5% if the recipient is a company holding at least 10% of the payer's capital, and 15% in other cases. The term 'dividends' includes income from shares and similar rights. Exceptions apply if the recipient has a business connection in the payer's State, where Articles 7 or 14 may apply. A State cannot tax dividends from a company resident in another State unless connected to a permanent establishment or fixed base within that State.
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