Dividend taxation: treaty limits source-state withholding on dividends to a capped rate when paid to a resident beneficial owner. Article 10 permits the residence State of the beneficial owner to tax dividends and allows the State of the payer's residence to tax those dividends subject to a treaty cap when the recipient is the beneficial owner resident of the other Contracting State. Dividends are defined to include income from shares and similar profit-participating rights. The reduced-rate provisions do not apply where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the payer's State, in which case business or professional income rules apply; the treaty also limits taxation of dividends and undistributed profits by the other State except in specified connected or resident circumstances.