Dividend taxation limits source-state withholding when recipient is the beneficial owner under the tax treaty.

Dividends paid by a resident company of one Contracting State to a resident of the other may be taxed in the recipient's State, and may also be taxed in the company's State of residence; if the recipient is the beneficial owner the tax charged by the source State is limited to a specified rate. The limitation does not affect taxation of the company's profits, and dividends effectively connected with a permanent establishment or fixed base are taxed under the Articles for business profits or independent personal services.

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