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of <h1>Dividends Taxed in Both States, Capped at 10% for Beneficial Owners in Other State; Exclusions Apply for Business Establishments.</h1> Dividends paid by a company resident in one Contracting State to a resident of the other Contracting State may be taxed in both states. However, if the beneficial owner resides in the other state, the tax in the company's resident state is capped at 10% of the gross dividends. 'Dividends' include income from shares or similar rights. The provisions do not apply if the beneficial owner conducts business through a permanent establishment or fixed base in the company's resident state. A state cannot tax dividends from a company resident in the other state unless paid to its resident or connected to a permanent establishment or fixed base.
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