Dividend taxation limits set by treaty restrict source-state withholding for beneficial owners, with holding-period and permanent-establishment exceptions.

Treaty permits both residence and source taxation of dividends but caps source-state withholding when the recipient is the beneficial owner. A lower cap applies where the beneficial owner is a company meeting an ownership threshold and a continuous 365 day holding requirement; a higher cap applies otherwise. The withholding limits do not apply if the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source state, where business-connection provisions govern. The treaty defines dividends as income from shares and similar profit-participating corporate rights.

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