Dividends withholding limits: source-state tax capped under treaty, reduced rates for substantial corporate shareholders with continuous holding. Taxation of dividends permits taxation by the recipient's State while allowing the paying company's State to tax dividends subject to treaty withholding limits: reduced rates apply for corporate beneficial owners meeting ownership and continuous holding conditions under the MLI, with higher rates otherwise. Company taxation on profits is unaffected and 'dividends' covers income from shares and analogous participatory rights. Withholding limits do not apply where the beneficial owner's holding is effectively connected to a permanent establishment or fixed base in the paying State, in which case rules for business profits or independent personal services govern; the paying State may not tax undistributed profits.