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of <h1>Taxation of Cross-Border Dividends: Capped at 10% if Beneficial Owner; Exclusions for Permanent Establishments</h1> Dividends paid by a company resident in one Contracting State to a resident of the other may be taxed in the recipient's state. They may also be taxed in the payer's state, but if the recipient is the beneficial owner, the tax is capped at 10% of the gross dividends. 'Dividends' include income from shares and similar rights. The provisions do not apply if the dividends are connected with a permanent establishment or fixed base in the payer's state. A state cannot tax a company's dividends or undistributed profits unless they are connected to a permanent establishment or fixed base within that state.
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