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<h1>Dividends Taxed at Max 10% for Foreign Residents; Exemptions for Permanent Establishments Apply Under Specific 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 may also tax these dividends, but the tax rate must not exceed 10% if the recipient is a resident of the other State. 'Dividends' include income from shares or similar rights. The provisions do not apply if the dividend recipient conducts business through a permanent establishment in the company's State. A State cannot tax dividends paid by a company from another State unless the recipient is a resident or the dividends are connected to a permanent establishment.