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of <h1>Article 10: Taxation on Dividends under DTAA with Armenia Capped at 10% for Beneficial Owners</h1> Article 10 of the Double Taxation Avoidance Agreement (DTAA) between Armenia and another contracting state addresses the taxation of dividends. Dividends paid by a company resident in one contracting state to a resident of the other state may be taxed in the recipient's state, but also in the state where the company resides, with a tax cap of 10% if the recipient is the beneficial owner. The definition of 'dividends' includes income from shares and similar corporate rights. Exceptions apply if the dividends are connected to a permanent establishment or fixed base in the payer's state, in which case other articles apply. The other state cannot impose tax on dividends or undistributed profits unless they are connected to a permanent establishment or fixed base within its jurisdiction.
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