Dividend withholding limits set maximum source tax on cross-border dividends, with reduced rates for substantial corporate shareholders and connection exceptions. Article 10 permits taxation of dividends in the recipient's State but limits source-state withholding by imposing maximum rates where the recipient is the beneficial owner, preserving source-State taxation of company profits while exempting Singapore from additional dividend taxation when it does not tax dividends beyond corporate profits. The Article defines dividends to include income from shares and similar participatory rights, and excludes the withholding limits where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, applying business profit or independent service provisions instead.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Dividend withholding limits set maximum source tax on cross-border dividends, with reduced rates for substantial corporate shareholders and connection exceptions.
Article 10 permits taxation of dividends in the recipient's State but limits source-state withholding by imposing maximum rates where the recipient is the beneficial owner, preserving source-State taxation of company profits while exempting Singapore from additional dividend taxation when it does not tax dividends beyond corporate profits. The Article defines dividends to include income from shares and similar participatory rights, and excludes the withholding limits where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, applying business profit or independent service provisions instead.
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