Dividend withholding tax cap limits source-state taxation under the treaty when the beneficial owner is resident of the other Contracting State. Article 10 limits source-state taxation of dividends paid to a resident beneficial owner of the other Contracting State by imposing a treaty cap on such taxation while preserving the taxing rights of the recipient State. The article excludes treaty relief where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case rules for business profits or independent personal services apply, and it restricts source States from taxing dividends or undistributed profits derived from the other Contracting State except in those specified circumstances.
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.
Dividend withholding tax cap limits source-state taxation under the treaty when the beneficial owner is resident of the other Contracting State.
Article 10 limits source-state taxation of dividends paid to a resident beneficial owner of the other Contracting State by imposing a treaty cap on such taxation while preserving the taxing rights of the recipient State. The article excludes treaty relief where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case rules for business profits or independent personal services apply, and it restricts source States from taxing dividends or undistributed profits derived from the other Contracting State except in those specified circumstances.
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