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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Dividends Taxed in Both States, Capped at 10% for Beneficial Owners Without Permanent Establishment; Includes Share Income</h1> Dividends paid by a company resident in one Contracting State to a resident of the other Contracting State may be taxed in both states. However, if the beneficial owner of the dividends resides in the other state, the tax in the state of the company's residence shall not exceed 10% of the gross dividends. The term 'dividends' includes income from shares or similar rights. The provisions do not apply if the beneficial owner conducts business through a permanent establishment in the company's state. A state cannot tax dividends paid by a company resident in the other state unless certain conditions are met.
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