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of <h1>Tax on Dividends: 15% Cap for Companies Owning 25% Shares, 25% Cap for Others Under Specific Rules</h1> Dividends paid by a company in one Contracting State to a resident of the other Contracting State may be taxed in the recipient's state. However, they may also be taxed in the state where the paying company resides, with a cap if the recipient is the beneficial owner. Specifically, if the beneficial owner is a company owning at least 25% of the shares, the tax is limited to 15% of the gross dividends, subject to certain ownership conditions. In other cases, the tax is capped at 25%. These provisions do not apply if the dividends are connected to a permanent establishment or fixed base in the paying company's state.
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