Dividend taxation under the Brazil treaty limits source-state withholding, defines dividends broadly, and excludes connected permanent establishment income. Dividends paid by a company resident in one Contracting State to a resident of the other Contracting State may be taxed in both States, but the source-State tax is limited to 10 per cent for a qualifying company beneficial owner holding at least 20 per cent of the payer's capital throughout the prescribed period, and 15 per cent in other cases. The article defines dividends broadly, excludes payments effectively connected with a permanent establishment or fixed base, caps withholding tax on a resident of India's permanent establishment in Brazil at 15 per cent of profits after corporate tax, and prevents the other State from taxing dividends or undistributed profits beyond the stated exceptions.