Dividend taxation: source-state withholding capped where recipient is beneficial owner, with permanent establishment exception applying. Dividends paid by a company resident in one Contracting State to a resident of the other may be taxed in the recipient's State, while the source State may also tax such dividends subject to a withholding limit where the recipient is the beneficial owner. The withholding 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 provisions on business profits or independent personal services apply.
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 capped where recipient is beneficial owner, with permanent establishment exception applying.
Dividends paid by a company resident in one Contracting State to a resident of the other may be taxed in the recipient's State, while the source State may also tax such dividends subject to a withholding limit where the recipient is the beneficial owner. The withholding 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 provisions on business profits or independent personal services apply.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
