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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Tax on Cross-Border Dividends Capped at 10% for Beneficial Owners Under Certain Conditions</h1> Dividends paid by a company resident in one Contracting State to a resident of the other may be taxed in the recipient's State. They may also be taxed in the company's State, but if the recipient is the beneficial owner, the tax cannot exceed 10% of the gross dividends. 'Dividends' include income from shares and 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 another State unless they are paid to a resident or connected with a permanent establishment.
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