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of <h1>Dividends Can Be Taxed in Both States, Capped at 10% if Recipient Is Beneficial Owner, Unless Exceptions Apply</h1> Dividends paid by a company resident in one State to a resident of another State may be taxed in the recipient's State. Additionally, such dividends can be taxed in the State where the company resides, but if the recipient is the beneficial owner, the tax cannot exceed 10% of the gross dividend amount. The competent authorities will agree on applying this rule. The term 'dividend' includes various forms of profit-sharing income. Exceptions apply if the beneficial owner conducts business or provides services in the company's State through a permanent establishment or fixed base. In such cases, other articles apply. A State cannot tax a company's dividends or undistributed profits unless connected to a permanent establishment or fixed base in that State.
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