Dividend taxation: cross-border source-state tax limited where beneficial owner is resident in the other Contracting State. Dividends paid cross-border may be taxed in the recipient's State; the payer's State may also tax such dividends but with a capped charge where the beneficial owner is resident of the other State. 'Dividends' includes income from shares and equivalent corporate rights, and treaty relief is excluded where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the payer's State, in which case rules on business profits or independent personal services apply.