Taxation of dividends: limited source-state withholding permitted, with residence-state taxation and permanent establishment exceptions applying. Taxation of dividends allows residence-state taxation while permitting the source State to tax dividends paid by resident companies to non-resident beneficial owners subject to a capped tax, defines dividends broadly to include profit-participating rights and similar corporate income, and excludes the source-state limitation where holdings are effectively connected with a permanent establishment or fixed base so that business profits or independent personal services provisions apply.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Taxation of dividends: limited source-state withholding permitted, with residence-state taxation and permanent establishment exceptions applying.
Taxation of dividends allows residence-state taxation while permitting the source State to tax dividends paid by resident companies to non-resident beneficial owners subject to a capped tax, defines dividends broadly to include profit-participating rights and similar corporate income, and excludes the source-state limitation where holdings are effectively connected with a permanent establishment or fixed base so that business profits or independent personal services provisions apply.
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