Dividend taxation: source-state withholding limited for beneficial owners of cross-border dividends, with permanent establishment exceptions applying. Dividends paid cross-border may be taxed in the recipient's State, while the source State may also tax them but must limit the tax where the recipient is the beneficial owner. The limitation does not apply if the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case the rules on business profits or independent personal services govern. The Article defines dividends as income from shares and similar corporate rights and restricts the other State from taxing such dividends or the company's undistributed profits except in 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 taxation: source-state withholding limited for beneficial owners of cross-border dividends, with permanent establishment exceptions applying.
Dividends paid cross-border may be taxed in the recipient's State, while the source State may also tax them but must limit the tax where the recipient is the beneficial owner. The limitation does not apply if the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case the rules on business profits or independent personal services govern. The Article defines dividends as income from shares and similar corporate rights and restricts the other State from taxing such dividends or the company's undistributed profits except in specified circumstances.
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