Dividend withholding limit restricts source-state tax on cross-border dividends, with exceptions for permanent establishment connections. Dividends paid to a resident of the other Contracting State may be taxed in the recipient's State and also in the source State, but where the beneficial owner is resident in the other State the source state tax on dividends is limited to a withholding not exceeding ten percent of the gross amount. 'Dividends' includes income from shares and similar profit participating rights. The withholding limitation is inapplicable when the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case rules on business profits or independent personal services govern; the source State may not tax such dividends or undistributed profits except in the specified circumstances.
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.
Dividend withholding limit restricts source-state tax on cross-border dividends, with exceptions for permanent establishment connections.
Dividends paid to a resident of the other Contracting State may be taxed in the recipient's State and also in the source State, but where the beneficial owner is resident in the other State the source state tax on dividends is limited to a withholding not exceeding ten percent of the gross amount. "Dividends" includes income from shares and similar profit participating rights. The withholding limitation is inapplicable when the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case rules on business profits or independent personal services govern; the source State may not tax such dividends or undistributed profits except in the specified circumstances.
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