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of <h1>Dividends Taxed in Both States: 5% Cap if Beneficial Owner Resides Elsewhere; Exclusions for Permanent Establishments.</h1> Dividends paid by a company resident in one Contracting State to a resident of the other Contracting State can be taxed in the recipient's state. However, they may also be taxed in the payer's state, but the tax should not exceed 5% if the beneficial owner resides in the other state. 'Dividends' include income from shares and similar rights. The provisions do not apply if the beneficial owner conducts business through a permanent establishment or fixed base in the payer's state. Additionally, a state cannot tax dividends paid by a company resident in the other state unless connected to a permanent establishment or fixed base there.
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