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of <h1>Taxation Rules on Dividends Between Contracting States: Maximum 10-15% Tax Rates Explained</h1> Dividends paid by a company resident in one Contracting State to a resident of the other Contracting State can be taxed in the recipient's state. However, the dividends may also be taxed in the company's resident state, with a maximum tax of 10% if the recipient company holds at least 10% of the paying company's capital, or 15% in other cases. The term 'dividends' includes income from shares and similar rights. These provisions do not apply if the dividend recipient has a permanent establishment in the paying company's state. Additionally, a state cannot tax dividends from a company resident in the other state unless connected to a permanent establishment.
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