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.

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