Taxation of dividends: source state may impose withholding capped under treaty, subject to permanent establishment and fixed base exceptions. Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, and the source State may also tax such dividends subject to treaty withholding limits when the recipient is the beneficial owner. Withholding caps vary by ownership threshold. These limits do not affect taxation of the distributing company's profits. The definition of dividends includes income from shares and assimilated items, and withholding limits do not apply where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case rules for business profits or independent personal services govern.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Taxation of dividends: source state may impose withholding capped under treaty, subject to permanent establishment and fixed base exceptions.
Dividends paid by a resident company to a resident of the other Contracting State may be taxed in the recipient's State, and the source State may also tax such dividends subject to treaty withholding limits when the recipient is the beneficial owner. Withholding caps vary by ownership threshold. These limits do not affect taxation of the distributing company's profits. The definition of dividends includes income from shares and assimilated items, and withholding limits do not apply where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case rules for business profits or independent personal services govern.
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