Introducing the “In Favour Of” filter in Case Laws.
- ⚖️ Instantly identify judgments decided in favour of the Assessee, Revenue, or Appellant
- 🔍 Narrow down results with higher precision
Try it now in Case Laws →
TaxTMI Login
🚀 New Feature Launched ✕
Just a moment...
Introducing the “In Favour Of” filter in Case Laws.
Try it now in Case Laws →
Press 'Enter' to add multiple search terms. Rules for Better Search
of 
of 
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of of 
All Acts & Rules
of of All Acts & Rules
Note
Bookmark
Share
Don't have an account? Register Here
of <h1>Dividends Taxed in Recipient's State, Capped at 15% in Paying State, Exemptions for Permanent Establishments</h1> Dividends paid by a company resident in one Contracting State to a resident of the other may be taxed in the recipient's State. However, they can also be taxed in the State of the paying company, but the tax should not exceed 15% if the recipient is the beneficial owner. The term 'dividends' includes income from shares and similar rights. The provisions do not apply if the recipient conducts business in the paying company's State through a permanent establishment or fixed base. A State cannot tax dividends paid by a company resident in another State unless connected to a permanent establishment or fixed base.
TaxTMI 
TaxTMI 
