Withholding tax on dividends limited where beneficial owner meets ownership and holding period conditions, otherwise a higher withholding applies. Taxation of cross border dividends permits taxation in the recipient's State while allowing the payer's State to tax dividends subject to limits when the recipient is the beneficial owner. A reduced withholding rate applies where a corporate beneficial owner meets ownership and continuous holding period requirements (with certain reorganisations disregarded); otherwise a higher rate applies. Dividends include income from shares and equivalent rights, and the Article excludes application where the holding is effectively connected with a permanent establishment or fixed base, in which case business profits or independent services rules apply.
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.
Withholding tax on dividends limited where beneficial owner meets ownership and holding period conditions, otherwise a higher withholding applies.
Taxation of cross border dividends permits taxation in the recipient's State while allowing the payer's State to tax dividends subject to limits when the recipient is the beneficial owner. A reduced withholding rate applies where a corporate beneficial owner meets ownership and continuous holding period requirements (with certain reorganisations disregarded); otherwise a higher rate applies. Dividends include income from shares and equivalent rights, and the Article excludes application where the holding is effectively connected with a permanent establishment or fixed base, in which case business profits or independent services rules apply.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
