Dividend taxation: source State may tax dividends while withholding capped for beneficial owners, with permanent establishment exceptions.

Article 11 of the Bulgaria DTAA permits the recipient's State to tax dividends but allows the source State to tax dividends paid by its resident companies subject to a capped tax where the recipient is the beneficial owner. It defines dividends to include share income and equivalent corporate rights, preserves taxation of company profits, provides an exception where holdings are effectively connected to a permanent establishment or fixed base (invoking business profits or independent services rules), and restricts the other State from taxing such dividends or undistributed profits except in specified resident or effectively connected cases.

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