Dividend withholding cap limits source taxation when recipient is resident; PE or fixed base connection invokes business taxation rules. Dividends paid cross border may be taxed in the recipient's residence, while the source State may also tax dividends but its withholding is capped where the beneficial owner resides in the other Contracting State. The Article defines dividends to include income from shares and similar profit participating rights. Withholding limits do not apply when the beneficial owner's holdings are effectively connected with a permanent establishment or fixed base in the source State, in which case business or independent service rules govern; the source State may not tax undistributed profits on that basis.