Dividend taxation cap limits source-state withholding on cross-border dividends where the beneficial owner is resident elsewhere. Article 10 sets rules for dividend taxation between the Contracting States: dividends may be taxed in the recipient's state, while the source state may also tax them but its tax on dividends paid to a beneficial owner resident in the other state is capped at ten percent of the gross amount. Dividends are defined to include income from shares and equivalent corporate rights. The Article excludes its withholding rules where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source state, in which case business profits or independent personal services provisions apply.