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of <h1>Cross-Border Dividend Tax: Max 15% Rate for Foreign Residents; Exemptions for Business Establishments Apply.</h1> Dividends paid by a company resident in one Contracting State to a resident of the other Contracting State may be taxed in the recipient's State. Additionally, the State where the company paying the dividends resides can also tax these dividends, but the tax rate should not exceed 15% if the recipient is a resident of the other State. The term 'dividends' includes income from shares or similar rights. The provisions do not apply if the dividend recipient conducts business through a permanent establishment in the State where the company resides. A company resident in one State cannot be taxed by the other State on dividends unless certain conditions are met.
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