Dividend taxation: source-state withholding limited when dividends are received by a beneficial owner resident in the other State. Article 10 permits the recipient's State to tax dividends while allowing the source State to impose a capped withholding tax on dividends paid to beneficial owners resident in the other Contracting State. 'Dividends' include income from shares and similar profit-participating rights. The reduced withholding does not apply where the beneficial owner conducts business in the source State through a permanent establishment or a fixed base and the holding is effectively connected; in such cases, rules for business profits or independent personal services apply. The source State may not tax dividends derived from the other State or undistributed profits except in specified connected circumstances.