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of <h1>Cross-Border Dividends: Taxation Capped at 10% in Payer's State Under Certain Conditions; Special Rules for Permanent Establishments.</h1> Dividends paid by a company resident in one Contracting State to a resident of the other Contracting State can be taxed in the recipient's State. However, they may also be taxed in the payer's State, but the tax cannot exceed 10% if the recipient is a resident of the other State. The term 'dividends' includes income from shares or similar rights. If the recipient operates a business or provides services through a permanent establishment in the payer's State, different tax provisions apply. A State cannot tax dividends paid by a company resident in the other State unless certain conditions are met.
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