Dividend taxation limits: residence and source states share taxing rights, with capped source withholding and PE exceptions.

Article 10 allocates dividend taxation between residence and source States: the recipient's residence State may tax dividends, while the source State may also tax them but subject to capped withholding where the recipient is the beneficial owner; substantive taxation of the distributing company's profits is preserved. The withholding limits do not apply when the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which event business profit or independent services rules govern. The source State is barred from taxing dividends or undistributed profits paid to nonresidents except as specified.

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