Dividend taxation under treaty limits source withholding, subject to permanent establishment and fixed base connection exceptions.

The treaty allows the recipient's State to tax dividends while the source State may also tax them but, if the recipient is the beneficial owner, source taxation is limited by a treaty withholding cap. Dividends cover income from shares and analogous corporate rights under source law. The withholding limit is inapplicable where the beneficial owner's holding is effectively connected with a permanent establishment or fixed base in the source State, in which case rules on business profits or independent personal services govern, and the source State cannot tax undistributed profits except as specified.

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