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of <h1>Dividends Taxed in Recipient's State; Capped at 15% for 10% Voting Power Holders, Subject to 365-Day Rule</h1> Dividends paid by a company in one Contracting State to a resident of the other may be taxed in the recipient's state. Additionally, the state where the company resides may also tax these dividends, but if the recipient is the beneficial owner, the tax is capped at 15% if the owner controls at least 10% of voting power, otherwise at 25%. This is subject to a 365-day ownership condition. The term 'dividends' includes income from shares and similar rights. Exceptions apply if the dividends are connected to a permanent establishment or fixed base in the other state.
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