Dividend taxation under treaty limits shields resident beneficiaries, with connection to permanent establishments and anti abuse constraints applying.

Article 10 governs taxation of dividends: the recipient's state may tax dividends, while the source state may also tax them subject to a treaty limit when the beneficial owner is resident in the other Party. Dividends are defined to include income from shares and equivalent corporate rights. Preferential treatment is excluded where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source state; in such cases, Articles on business profits or independent personal services apply. Treaty benefits are denied where share creation or assignment was primarily to obtain treaty relief.

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