Dividend withholding tax limits restrict source-state taxation on cross-border dividends, with special rules for connected establishments. Dividends paid cross-border may be taxed in the recipient's State, but the source State may also tax such dividends subject to treaty withholding limits when the recipient is the beneficial owner; preferential treatment is provided for substantial corporate shareholders. The term dividends includes income from shares and similar rights. Withholding limits do not apply where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case business or service provisions apply, and the source State generally may not tax undistributed profits for non-residents.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Dividend withholding tax limits restrict source-state taxation on cross-border dividends, with special rules for connected establishments.
Dividends paid cross-border may be taxed in the recipient's State, but the source State may also tax such dividends subject to treaty withholding limits when the recipient is the beneficial owner; preferential treatment is provided for substantial corporate shareholders. The term dividends includes income from shares and similar rights. Withholding limits do not apply where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case business or service provisions apply, and the source State generally may not tax undistributed profits for non-residents.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
