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of <h1>Dividends Taxed in Recipient's State; Paying State Can Tax Up to 7.5% if Recipient is Beneficial Owner</h1> Dividends paid by a company in one Contracting State to a resident of the other Contracting State can be taxed in the recipient's state. However, the state of the company paying the dividends can also tax them, but the tax rate should not exceed 7.5% if the recipient is the beneficial owner. Dividends are defined as income from shares or similar rights. The provisions do not apply if the recipient has a permanent establishment or fixed base in the company's state, in which case other articles apply. A state cannot tax dividends or undistributed profits of a company from the other state unless specific conditions are met.
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