Dividend withholding limit restricts source-state tax on cross-border dividends, subject to beneficial ownership and permanent establishment exceptions. Dividends paid by a resident company may be taxed in the recipient's State, but the company's State may also tax those dividends subject to a capped source-State charge if the recipient is the beneficial owner; this does not affect taxation of the company's profits. The dividend definition covers income from shares and similar profit-participating corporate rights. The preferential treatment is excluded where the beneficial owner's dividends are attributable to a permanent establishment or fixed base in the payer-State, in which case business profit or independent services rules apply, and the payer-State is restricted from taxing dividends paid to non-residents or the company's undistributed profits except in specified circumstances.