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of <h1>Taxation on Dividends: Limitations and Exceptions for Cross-State Beneficiaries Under Specific Conditions</h1> Dividends paid by a company residing in one Contracting State to a resident of the other Contracting State can be taxed in the latter. However, the State where the company resides may also tax these dividends, but not exceeding 10% if the beneficial owner resides in the other State. 'Dividends' include income from shares and similar rights. Exceptions apply if the beneficial owner conducts business or services through a permanent establishment in the company's State. A Contracting State cannot tax dividends or undistributed profits from a company resident in the other State unless connected to a permanent establishment in the taxing State.
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